- 29 - Hagerman testified regarding petitioner’s representation of the six dancers in 1988. She was asked how much she anticipated their representation would cost at the time of their arrest. She replied: “At the time I thought around $20,000 apiece if each one had their own attorney if they didn’t want us to represent-- the corporation to represent them.” When asked whether she meant that petitioner was prepared to pay this amount, she confirmed that that was not the case: petitioner would have covered their legal expenses only if they did not want their own individual attorneys. Thus, while we know that petitioner paid for the dancers’ defense, we do not know how much petitioner’s management expected this representation would cost. The amount petitioner actually spent to defend the dancers was clearly much less than the amount Hagerman believed it would have cost the dancers to secure their own representation. The arrests occurred in June 1988, the trial June 1989. On its Forms 1120 for TYE 8/31/88 and TYE 8/31/89, petitioner reported aggregate legal expenses in the amounts of $24,501 and $52,951, respectively. Petitioner presented no evidence that any amount was set aside for the dancers’ defense. Even if some specific amount was set aside, this fact would not explain accumulations in any of the taxable years at issue, since the evidence indicates that the representation concluded before the end of the first of these years. Based on the amounts petitioner actually spent for the dancers’ defense in TYE 8/31/88 and TYE 8/31/89, we are notPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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