- 38 - Respondent allowed some of these expenses in the notice of deficiency, and we have identified additional promotional expenses in section II.C.1., above. In addition, although SCC may not deduct certain capital legal fees, see supra section II.C.2., we are convinced that those items were of no personal benefit to Mr. Strong. These items, which are not constructive dividends to Mr. Strong, are $2,835 in 1993 (check No. 6834) and $4,000 in 1994 (check No. 7763). Either the remaining income items disallowed as deductions to SCC were used by Mr. Strong for personal benefit or he has failed to show that they were not so used. He made no distinction between SCC’s funds and his own, by his own admission. He paid child support, medical bills, clothing, groceries, travel, and other personal expenses directly out of account No. 893315300. In addition to failing to properly substantiate his travel expenses, he has not shown that the travel expenses were not personal. He has failed to establish that the remaining nondeductible corporate expenditures had any legitimate corporate purpose and were not for his benefit. In summary, the deposits into account No. 893315300 determined to be taxable to SCC are taxable to Mr. Strong as constructive dividends, less the amounts of (1) the expenses allowed by respondent, (2) the promotional expenses we have heldPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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