IRS & the Burden to Prove Constructive Dividends

Using Warrants To Make Future Purchases Of S Corporation Stock

When a C corporation pays expenses for its shareholder, the payment can be subject to income tax for the shareholder as a constructive dividend. One defense is that the expenses for the C corporation were legitimate. Does the taxpayer have to prove the amount of the expenses or does the IRS? The Combs v. Commissioner,…