- 31 -- 31 -
the parties stipulated as follows:
24. Petitioners made the following paryments [sic] in
1989:
$474,467.56 Payments to Corporation
6,584.06 Payments of Corporate Expenses
* * * * * * *
27. Petitioners made the following payments in 1990:
$52,462.00 Payments to Corporation
3,693.40 Payments of Corporate Expenses
Under the foregoing unqualified stipulations, the parties have
agreed that during 1989 and 1990 petitioners made payments to, or
on behalf of, K & H in the amounts of $481,051.62 and $56,155.40,
respectively.
On brief, petitioners appear to maintain that the foregoing
stipulations set forth the minimum payments that they made and
that they made additional payments during those years to, or on
behalf of, K & H and Ms. Velilla that increased the aggregate
amounts of such payments for 1989 and 1990 to $529,023.92 and
$89,643.25, respectively.19 To support their contention, they
rely on (1) petitioners’ schedules of expenses and (2) Ms. Harp's
testimony. Respondent disputes petitioners' contention.
19 Contrary to petitioners' position on brief, petitioner testi-
fied that the aggregate amount of the deposits into petitioners'
accounts during each of the years at issue of K & H's funds and
Ms. Velilla's funds were used to make payments to, or on behalf
of, K & H and Ms. Velilla. We question the reliability of that
testimony. Petitioner's testimony on that point also is incon-
sistent with petitioners' schedules of expenses that purport to
show that only a portion of those deposits were used to make
payments to, or on behalf of, K & H and Ms. Velilla.
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