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disallowed deductions for reimbursements of expenses for which
petitioners lacked substantiation; (3) the constructive dividends
to petitioner; and (4) the items they conceded. The Bolers did
not show good faith with regard to the claimed interest payments
because they offered no records or other documentary evidence
(other than the promissory note) of petitioner’s alleged loan to
AIM. There is no evidence about what information they gave their
accountants or how the accountants advised them to treat the
claimed interest payments or other items on which they did not
prevail. Petitioners did not show that their reliance on their
accountants explains their failure to keep adequate records for
AIM or the fact that AIM claimed business deductions for its
reimbursement of some of the Bolers’ personal expenses.
To reflect the foregoing,
Decisions will be
entered under Rule 155.
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