(petitioners, married couple, used husband's construction business to fund personal gambling habits; IRS failed to show that withdrawals from business bank account was taxable income to petitioners as opposed to a nontaxable return of capital or loan repayment; IRS bore burden of proof due to raising deemed distribution argument on post-deficiency basis).
CALT does not provide legal advice. Any information provided on this website is not intended to be a substitute for legal services from a competent professional. CALT's work is supported by fee-based seminars and generous private gifts. Any opinions, findings, conclusions or recommendations expressed in the material contained on this website do not necessarily reflect the views of Iowa State University.