G.B. Data Systems, Inc. - Page 7




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          under which petitioner served as the disbursing agent for them.7              
          As such, petitioner maintained approximately five or six bank                 
          accounts on behalf of those corporations, including an investment             
          account, a payroll account, and other disbursement accounts.  The             
          Braswell sales corporations for which petitioner served as the                
          disbursing agent deposited certain funds into the payroll and                 
          other disbursement bank accounts that petitioner maintained on                
          their behalf.  Thereafter, petitioner disbursed those funds on                
          behalf of those corporations in order to make payments, inter                 
          alia, for the respective payroll and other liabilities and debts              
          that those corporations incurred.  Petitioner’s disbursements of              
          funds on behalf of those corporations included disbursements of               
          funds that were payable to CMC under the Vita-CMC agreement.                  
               In return for the services that it provided to the Braswell              
          sales corporations over a period of time not established by the               
          record herein, petitioner received an administrative fee from                 
          those corporations.  That administrative fee, which was the                   
          source of most of petitioner’s income during that period, was                 
          calculated on the basis of a formula which, although not specifi-             
          cally described in the record in this case, took into account the             
          services that petitioner provided to each of the Braswell sales               
          corporations and the volume of business that each of those                    



               7It is not clear from the record whether other Braswell                  
          companies used petitioner as a disbursing agent.                              





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