Kenneth B. and Linda R. Satlin - Page 9

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          Petitioners have neither alleged that section 7491(a) applies nor           
          established their compliance with the requirements of section               
          7491(a)(2)(A) and (B) to substantiate items, maintain all                   
          required records, and cooperate fully with respondent’s                     
          reasonable requests.                                                        
          I.  Expenditures on Behalf of ITG                                           
               Section 162(a) allows a deduction for all the ordinary and             
          necessary expenses paid or incurred during the taxable year in              
          carrying on any trade or business, including a taxpayer’s trade             
          or business as an employee.  See Primuth v. Commissioner, 54 T.C.           
          374, 377-378 (1970).                                                        
               As a general rule, a taxpayer’s payment of another person’s            
          obligation is not an ordinary and necessary business expense.               
          Deputy v. du Pont, 308 U.S. 488 (1940).  For Federal income tax             
          purposes, a corporation’s business is separate from the business            
          of its shareholders, officers, and employees.  See Leamy v.                 
          Commissioner, 85 T.C. 798 (1985) (shareholders, officers and                
          employees may not deduct as personal expenses those expenses that           
          further the business of the corporation).                                   
               Because a corporation’s business is distinct from that of              
          its shareholders, officers, and employees, such persons may not             
          deduct expenses which promote the business of the corporation.              
          Leamy v. Commissioner, supra; Kahn v. Commissioner, 26 T.C. 273             
          (1956); Das v. Commissioner, T.C. Memo. 1998-353.   Payments by             






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