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46 checks were issued to Wedgewood on behalf of petitioner. The
payments represented by the 46 checks were shown on the books of
Culnen & Hamilton as shareholder loans. The 46 checks were
deposited into a bank account of Wedgewood, and their receipt was
shown on the books of Wedgewood as indebtedness to petitioner.
At some point during the years in issue, there was a reduction of
$375,000 in the total amount of $4,034,017.41 shown on the books
of both Wedgewood and Culnen & Hamilton to reflect partial
repayments.
On 28 occasions, from April 1989 through March 1992, Culnen
& Hamilton issued checks in payment of expenses of Wedgewood’s,
in amounts totaling $501,918.22 (the 28 checks).3 The payments
represented by the 28 checks were shown on the books of Culnen
& Hamilton as officer loans and on the books of Wedgewood as
indebtedness to petitioner.
On six occasions, from February 1987 through August 1990,
Culnen & Hamilton issued checks in payment of, or with respect
2(...continued)
1990 6,070.00
Total 4,034,017.41
3 The amounts for each year are as follows:
Year Amount
1989 $97,078.50
1990 404,130.86
1991 683.86
1992 25.00
Total 501,918.22
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