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All of the notes are signed, in what appears to be the same ink,
by petitioner as president of GAPS. On Schedule L of its 1988
and 1989 U.S. corporation income tax return forms, GAPS showed
liabilities as of the beginning and end of each year in the
following amounts:
Schedule L Entry as of: 1/1/88 12/31/88 1/1/89 12/31/89
Loans from stockholders --- --- --- $8,281
Notes payable in less than 1 yr. $36,427$31,637 $31,637 16,356
Notes payable in 1 yr. or more48,686 38,686 38,686 38,686
In 1989, GAPS paid $119,760 either directly to petitioner or
on his and his family's behalf.3 In 1989, GAPS had $65,376 of
8 17,061.02 12/31/89 12/31/90 12/31/90
9 8,281.04 12/31/89 12/21/90 12/31/90
10 38,686.05 12/31/89 12/31/90 12/31/90
3The parties introduced stipulated Exhibit 14-N which
purports to include the total amounts of corporate payments made
by GAPS and JJM to petitioner or on his or his family's behalf.
The amounts and applications of all corporate payments to
petitioner were as follows:
DESCRIPTION AMOUNT DESCRIPTION AMOUNT
Auto payments $6,887.76 Cable $645.90
Home insurance 971.00 ConEd 1,949.28
Home insurance 2,060.00 Gas 1,882.21
Carsons 2,484.86 Telephone 1,650.33
Chembank 9,461.73 Equipment 14,383.11
Fields 1,576.81 Advertising 2,394.47
Sears 440.19 Commissions 47,140.49
State use tax 525.00 Personal auto 395.00
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Last modified: May 25, 2011