Bell Capital Management, Inc. v. Commissioner, T.C. Memo. 2021-74 | June 14, 2021 | Wells, J. | Dkt. No. 21714-07
Short Summary:
A single shareholder (“Shareholder”) owned 100% of the stock and served as the sole director for the petitioner. For a period of 5 years, petitioner paid the Shareholder wages until a change in compensation structure. Moving forward, petitioner leased the Shareholder’s services through offshore employee leasing transactions (OEL transactions). During this period, petitioner furnished Shareholder with space to perform personnel services, loaned Shareholder an automobile for business use, and provided health insurance benefits, at petitioner’s cost. Additionally, Shareholder signed petitioner’s Form 1120S, in his capacity as president. Shareholder, further, listed himself on an annual corporate registration as CEO, CFO and President, as well as, admitted such status to the SEC as part of a settlement. After the years of exclusive service to the petitioner (“Years at Issue”), Shareholder began leasing his services to other operations.
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