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(2) January 1 through May 21, 1989; and (3) the month of October
1989. Petitioners did not provide respondent with PWIC’s general
ledgers for the periods: (1) June 1 through September 30, 1989;
and (2) November 1 through December 31, 1989.
Petitioners provided respondent with PWIC’s canceled checks
from May 29 through December 31, 1986. Petitioners did not
provide respondent with PWIC’s canceled checks from January 1
through December 31, 1989.
C.B. Crest
Petitioners purchased C.B. Crest with the intention of
consolidating or merging the Aqualator corporations into it. No
consolidation or merger took place.
During the 1989 fiscal year, C.B. Crest used the assets of
the Aqualator corporations. C.B. Crest rented out and
occasionally sold vending machines, as well as home, office, and
commercial water purification systems. In 1989, C.B. Crest
operated (including collecting the revenues and paying the
expenses) 551 water vending machines.
C.B. Crest paid petitioners the following amounts during the
taxable year 1989:
Payee Amount Reason Date
Mrs. Bowden $16,710.83 Unidentified Jan.-July 1989
Mrs. Bowden 105.04 Postage Jan. 1989
Mrs. Bowden 127.02 Rent July 1989
Mrs. Bowden 51,679.84 Salary Jan.-July 1989
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