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by the corporation to pay the personal expenses of its sole
shareholder were held not to be loan repayments. In that case,
the taxpayer did not testify, and the only evidence of a loan was
the accountant’s testimony. There were no loan agreements or
other documentary evidence relating to the alleged loans. Id.
Like Smith v. Commissioner, supra, petitioner has not
convinced this Court that Mr. Henderson made bona fide loans to
the corporation during the years in issue. In this case, neither
Mr. Henderson nor any other officer or employee of petitioner
testified as to the existence of any such loans. Petitioner
primarily relies on the testimony of Mr. Smith, the corporation’s
accountant. Mr. Smith testified that, other than the $9,000
promissory note, there were no written agreements or notes
evidencing additional loans. Specifically, Mr. Smith testified
that the only record of the purported loans indicated by the 1995
and 1996 corporate resolutions were found in petitioner’s own
general ledger. Such records, absent objective evidence of a
loan, will be given little weight. Dixie Dairies Corp. v.
Commissioner, supra at 495. Petitioner provided no other
receipts, bank statements, or canceled checks evidencing the
receipt by the corporation of the amounts purported to have been
loaned by Mr. Henderson. Mr. Smith testified that the purported
loans evidenced by the 1995 and 1996 corporate resolutions did
not provide for interest, repayment terms, or enforcement rights
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