Norton M. Bowman - Page 15

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          increase in shareholder loans of approximately $123,000, while              
          the 1987 corporate income tax return reports a decrease in those            
          loans of $125,000.5  The record does not suggest that any                   
          transactions other than the ones in issue could have affected               
          those figures.  Moreover, petitioner testified that he accepted a           
          sum approximating the amount he had paid on Associates' behalf in           
          settlement of his "loan".  Petitioner may therefore have received           
          only the distribution to which the parties have stipulated while            
          Associates may have treated the full amount of the "loan" as                
          having been discharged for reporting purposes regardless of any             
          discrepancy between the two amounts.                                        
                                                                                     
               Accordingly, we find that petitioner received only                     
          $117,164.91 from Associates during 1988.                                    
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          






          5    Respondent notes that the 1987 corporate return may reflect            
          payments made during calendar year 1987 as well as the                      
          distribution that occurred during 1988 because Associates used a            
          tax year ending Sept. 30, 1988.  However, any distribution that             
          petitioner might have received during 1987 would not be taxable             
          to him for 1988, the year in issue.  Petitioner, moreover,                  
          testified that he received no distributions from the corporation            
          prior to 1988.                                                              




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