ACM Environmental Services, Inc. et al. v. Comr., T.C. Memo. 2012-335

(petitioner and wife transferred approximately $250,000 to their corporation over three-year period, and used personal credit cards for both personal and business purchases; corporation paid credit card expense of almost $900,000; no records separating out business from personal expenses; court disallowed corporate deduction for personal expenses and such amounts included in couple's gross income; transfers to corporation constituted capital contributions rather than loans because no debtor-creditor relationship intended, and payment of personal expenses by corporation characterized as dividends; accuracy-related penalty imposed).