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Michell and shall be paid directly to Dinan, Inc. as
follows:
$7,000.00 each month is payable to Dinan, Inc. as
a consulting fee for the services of Mr. Hardtke
and Mr. Michell. It will be accounted as $4,000
for Mr. Hardtke and $3,000 for Mr. Michell.
The only persons present at the March 3, 1987 Agency board
meeting were Mr. Hardtke, Mr. Michell, and petitioner Nancy
Hardtke (Ms. Hardtke).
Agency's books of account for the period February 28, 1987,
through February 28, 1988, show entries reflecting that Agency
paid a total of $74,000 to Dinan as "consulting fees".3 Its
books of account for the period January 1, 1987, through December
31, 1987, do not contain any entries showing that compensation
was paid to Mr. Hardtke during 1987.
The books and records of Dinan for the period January 1,
1987, through December 31, 1987, do not contain any entries
showing that compensation was paid to Mr. Hardtke during 1987.4
Mr. Hardtke received the following compensation from Agency
and Dinan for the years 1986 and 1988:
Year Agency Dinan
1986 $3,000 $56,500
1988 65,600 38,535
3 It is not clear from the record whether all of those payments
were made during 1987.
4 Although during all relevant times Dinan used a fiscal year
that ended on the last day of February, the parties stipulated to
Dinan's books and records for the period Jan. 1, 1987, through
Dec. 31, 1987, when agreeing that those books and records do not
show any compensation paid to Mr. Hardtke during that year.
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