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They argue that “an employer cannot be his own employee” and that
no other person controlled petitioner in his work for NHIL. To
accept petitioners’ contentions that there was a lack of control
over petitioner would be the equivalent of disregarding the
corporate form in which petitioner chose to conduct his business.
Caselaw does not permit a taxpayer to use his or her dual role as
a shareholder of and service provider to a corporation as grounds
for ignoring the legal ramifications of the business form he
selected. See Moline Props., Inc. v. Commissioner, 319 U.S. 436,
438-439 (1943); Joseph M. Grey Pub. Accountant, P.C. v.
Commissioner, supra at 129.
Respondent properly recharacterized petitioner’s income as
wages and disallowed petitioners’ Schedule C deductions.
Petitioners claim that they are entitled to deductions not
previously claimed for business expenses, mortgage interest, and
real estate tax payments for 1996. Respondent has conceded
petitioners’ deductions for mortgage interest and real estate
taxes.
Petitioners claim that checks were written from their
accounts for various expenses that would have been deductible if
they had itemized their deductions at the time of filing their
return. Petitioners argue that respondent should have provided
these checks to the Court. However, petitioners bear the burden
of showing their entitlement to deductions. Rockwell v.
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