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Originally Posted by farmer_giles_of_ham
This is exactly the point: property vs income. It matters not so much of this other stuff, personal status, regulations etc, although these are also important...if it's private property its not income!
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That wasn't the basis of the Court's decision. If the corporation had had earnings and profits, the money Mr. Boulware diverted for his personal purposes would have been taxable as a dividend, regardless of the fact that upon receipt the money might be his private property (although it might also have been stolen funds, which would be taxable income as well).