WSB Liquidating Corporation - Page 15

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          marital home and divisions of various marital property.  However,           
          the language of the Settlement Agreement belies petitioner’s                
          position; Barbara waives her rights to alimony in exchange for              
          the “pension payment and benefits as herein set forth” and in               
          context these “benefits” refer to the health insurance and                  
          automobile fringe benefits that are outlined immediately before.            
               To the extent the payments relieved Walter of his obligation           
          to pay alimony, they are nondeductible by petitioner.  A                    
          corporation’s payment of its shareholder’s personal expense or              
          obligation is not deductible by the corporation.  See Greenspon             
          v. Commissioner, 229 F.2d 947 (8th Cir. 1956), affg. in part and            
          revg. in part 23 T.C. 138 (1954); Enoch v. Commissioner, 57 T.C.            
          781 (1972); American Properties, Inc. v. Commissioner, 28 T.C.              
          1100 (1957), affd. per curiam 262 F.2d 150 (9th Cir. 1958).  This           
          Court has found in circumstances similar to the present ones that           
          payments made by a closely held corporation to the former spouse            
          of a controlling shareholder and claimed as deductible                      
          compensation or other business expense were disguised alimony or            
          part of a property settlement and therefore nondeductible                   
          personal expenditures of the shareholder.  See J.B.S. Enters.,              
          Inc. v. Commissioner, T.C. Memo. 1991-254;  Greenwood v.                    
          Commissioner, T.C. Memo. 1989-368; Frankland Racing Equip., Inc.            
          v. Commissioner, T.C. Memo. 1987-210.  These cases concerned                
          situations where the shareholder’s spouse had at no time rendered           

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