Leon L. Sicard and Eleanor Sicard - Page 7

                                        - 7 -                                         
          the management fees accruing to petitioner pursuant to the                  
          compensation arrangement.                                                   
               During February 1984, Mr. White instructed Mr. Davis to                
          prepare an invoice for the fees earned by petitioner and White              
          Enterprises from June 1983 through February 1984 and thereafter             
          to prepare invoices for these fees and to record the fees in the            
          partnership’s books and records on a monthly basis.  From                   
          February 1984 through December 1986, Mr. Davis prepared an                  
          invoice each month for the fees owed to petitioner and White                
          Enterprises.  The fees earned by petitioner were recorded in the            
          partnership’s books and records as amounts payable and as                   
          management fees added to the cost of goods sold.  The management            
          fees that accrued to petitioner were capitalized into inventory             
          each year by Mr. Davis and expensed as the inventory was sold.              
               The partnership’s records reflect the following management             
          fees that accrued to petitioner at the rate of $5,000 per month             
          pursuant to the compensation arrangement:                                   
                         Year           Amount                                        
                         1983           $35,000                                       
                         1984           60,000                                        
                         1985           60,000                                        
                         1986           60,000                                        
               From June through December 1983, the partnership accrued               
          $5,000 per month to White Enterprises.  From January 1984 through           
          December 1986, the partnership accrued or paid between $9,000 to            
          $10,000 per month in construction and other fees to White                   






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011