Allied Marine Systems, Inc. - Page 8

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               Respondent concedes that Allied's income in 1989 should be             
          reduced by $1,700 to reflect loans to employees that were repaid            
          during 1989.  Allied's argument is that all of the loans to                 
          employees were repaid in the year that the loans were made and,             
          thus, that Allied's income should be reduced by the total amount            
          of the loans to employees in 1988 and 1989.                                 
               Allied's cash receipts and disbursements journals for 1988             
          and 1989 were introduced as evidence.  None of the deposits were            
          either identified as loan repayments or traceable to particular             
          loans.  Except for the $1,700 that was conceded by respondent, no           
          indication is given in the journals that any other loans to                 
          employees were repaid during 1988 or 1989.  Petitioner's general            
          and uncorroborated testimony is not sufficient to prove that                
          Allied's loans to employees were in fact repaid during the same             
          year that they were made, and the December dates of some loans              
          suggest otherwise.  Respondent's determination regarding                    
          adjustments to Allied's income, as modified by her concession,              
          will be sustained.                                                          
               Allied also contends that respondent's determination of                
          Allied's expenses for the operation of petitioner's airplanes               
          should be increased by $2,000 and $14,675 in 1988 and 1989,                 
          respectively.  Respondent argues that Allied is not entitled to             
          additional airplane expenses.                                               
               For 1988 and 1989, Allied argues that it is entitled to                
          additional depreciation deductions related to petitioner's                  




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