-10-
Year Payor Amount
1979 Not specified $695,176 Can
1980 RLLC 18,195 Can
LPH 150,000 Can
1981 RLLC 18,109 Can
LPH 50,000 Can
personal use of corporate car 2,640 Can
1982 RLLC 43,228 Can
1983 RLLC 155,175 Can
Petitioner 364,185 Can
1984 Petitioner 7,500 Can
1985 Petitioner/Anchor Wate joint venture 110,000
Petitioner/Texas Coating Supply 52,252
joint venture
1986 Petitioner/Anchor Wate joint venture 120,000
Petitioner/Texas Coating Supply 22,748
1987 Petitioner (bonus) 1,680,000
(wages) 97,700
Environmental Builders, Inc. 21,000
1988 LPCC 1,176,684
The reasonableness of the $1,777,700 ($1,680,000 bonus plus $97,700
wages) payment to Mr. Leonard from petitioner in 1987 is at issue
herein.6
We note that Mr. Leonard also received dividends from RLLH in
1983 and 1984 in the respective amounts of Can$500,000 and
Can$200,000.
6 Petitioner issued a check to Mr. Leonard on Sept. 28,
1987, and Mr. Leonard deposited it in his personal bank account.
Simultaneously, Mr. Leonard transferred $289,703 of the bonus
back to petitioner. While the record is unclear as to why Mr.
Leonard remitted the $289,703 to petitioner, it appears he
believed that he owed petitioner this amount.
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