-27- Nor do we find any evidence of payment of rent by Arbor to petitioner, so as to justify writing off the office expenses by him personally, in his capacity as a landlord, under section 212. Sec. 1.212-1(h), Income Tax Regs. (second sentence). As enunciated by the Supreme Court, the “doctrine of corporate entity” fills a useful purpose in business life, and whether the purpose be to gain an advantage under law of the State of incorporation, so long as that purpose is the equivalent of business activity, the corporation remains a separate taxable entity. Moline Props., Inc. v. Commissioner, 319 U.S. 436, 438 (1943). Short of disregarding the corporate integrity of Arbor for petitioner’s benefit, we see no basis for allowing petitioner to personally expense Arbor’s office costs. We hold that the $14,065 of office expenses may not be deducted by petitioner. We have considered all arguments of the parties related to our holdings set forth herein and, to the extent not discussed herein, find those arguments to be irrelevant or without merit. Decision will be entered under Rule 155.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
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