Moacir Santos v. Commissioner

T.C. Memo. 2019-148

UNITED STATES TAX COURT MOACIR SANTOS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11847-15. Filed October 31, 2019. Moacir Santos, for himself. David M. Carl and Trent D. Usitalo, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GUSTAFSON, Judge: Petitioner Moacir Santos operated an engineering and paving company through his wholly owned C corporation, Santos Engineering Santos Pavers, Inc. (“SESP”). Throughout 2010 Mr. Santos used SESP’s bank account to make cash withdrawals, electronic transfers to his personal bank account, and payments…