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stand, what petitioner and his corporations have done would make
corporate income disappear completely from the income tax system.
Although these cases concern taxes at both the corporate and
individual levels, and were properly consolidated for trial,
briefing, and opinion, respondent's and petitioners'
presentations have blurred the corporate and individual tax
issues. For example, the relationships between the disallowed
corporate deductions and the corporate payments to petitioner are
not shown anywhere in the record. We have the $212,380 total of
the corporate payments in joint exhibit 14-N. However, we are
unable to determine how respondent apportioned the $212,380 total
amount of corporate payments listed in exhibit 14-N between GAPS
and JJM. At trial and on brief, respondent continually referred
to GAPS and JJM as one entity for purposes of determining the
amount of corporate distributions. However, the statutory notice
apportions corporate distributions between GAPS and JJM, in the
amounts of $105,220 and $40,208, respectively. We have had to
review a spotty record to try to glean the actual amounts that
GAPS and JJM each paid to and for petitioner.8
8Respondent made two adjustments to the amount of total
payments of $212,380.35 to arrive at the amounts of taxable
corporate distributions determined in the statutory notice. One
of the adjustments was for the amounts listed as shareholder
loans on the GAPS and JJM corporate income tax returns for 1989.
The other adjustment was for amounts that petitioner reported on
his individual return. This included the $38,412 of payments
from Mass Mutual deposited in the corporate account, the $4,000
of wages from JJM, and the $6,259 of non-employee compensation
(continued...)
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