(petitioner sold S corporation stock to ESOP and remained involved in S corporation business after sale, and paid for non-business expenses from corporate account which were recorded in ledger account; corporation, on behalf of petitioner, made significant charitable contributions and IRS denied deductibility because petitioner fully paid ledger account balances with personal funds and was the party that bore economic burden of such contributions; in latter half of year in which contributions made, petitioner used corporate funds to pay off ledger account balances previously incurred; court determined that S corporation actually bore economic burden of contributions; but, court determined that petitioners did not prove the portion of contributions made in latter half of tax year made with personal funds and did not establish with sufficient evidence that ledger account balances were bona fide debt of petitioner; as a result, associated deductions denied).