Case brief

When the company checkbook becomes a second wallet.

Prezioso v. Commissioner, T.C. Memo. 2026-63, decided July 28, 2026. The Tax Court called it fraud, and the paper trail is why.

The takeaway

Every dollar that crosses the line needs a name.

Wages, distribution, loan, or reimbursement: the label has to be assigned when the money moves, in books that say the same thing the return says. If you want a written read on where your own setup stands, that is what the free Tax Position Review is for.

Book your free Tax Position Review

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