Barry B. Bealor and Nancy L. Bealor, et al. - Page 18

                                       - 107 -                                        
          and explained:                                                              
               This argument is meritless because both corporations                   
               were controlled by * * * [a promoter] * * *; while in                  
               theory such interference might have occurred, it was                   
               realistically impossible.  Therefore, we conclude that                 
               the transactions that resulted in the circular flow of                 
               the $900,000 proceeds of the bank loans were shams                     
               entered into solely to create the illusion of research                 
               and experimental expenditures, while in substance                      
               insuring that no part of such funds would be so used.                  
               [Id. at 1346.]                                                         
               In Karme v. Commissioner, 73 T.C. 1163 (1980), affd. 673               
          F.2d 1062 (9th Cir. 1982), the taxpayer, in an effort to reduce             
          his taxes, purportedly borrowed money to purchase stock in a                
          corporation.  The purchase would take place "if and when" a                 
          public offering of that corporation's stock occurred.  The                  
          resulting transactions, designed by Harry Margolis, all occurred            
          on December 16 and 17, 1969.  They began with the taxpayer's                
          borrowing $600,000 from the Union Bank in California.  That bank            
          then wired that amount to the account of a company named World              
          Minerals at Banco Popular in the Netherlands West Antilles.  The            
          $600,000 then moved to another account, held by an entity named             
          Alms, at the Banco Popular.  Alms then "loaned" that amount to              
          the taxpayer by transferring it to the taxpayer's Union Bank                
          account.  On December 17, 1969, Union Bank used the amount to               
          repay the taxpayer's loan.  The taxpayer wrote a check to Alms              
          for $60,000 as interest, but only after receiving a $50,000 loan            
          from another Margolis entity named Anglo-Dutch Capital.  (The               
          $10,000 difference was later credited to the taxpayer for his use           





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