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tions to these transfers. Included in the amounts transferred
for petitioner's benefit by Goshorn was $5,725.02 to Ray Weigel,
Inc. No amounts were credited as reductions to the transfers
from Goshorn to Ray Weigel, Inc., during Goshorn's tax year
ending October 31, 1988. Thus, there was a net transfer to
petitioner for the tax year ending October 31, 1988, of
$181,935.92. As of October 31, 1988, Goshorn reported unappro-
priated retained earnings of $990,035.
For its tax year ending October 31, 1989, Goshorn made two
separate transfers to petitioner or to entities solely owned by
petitioner.
First, Goshorn recorded a transfer of $126,126 to Technical
Packaging, Inc., d.b.a. Tek-Pak (Tek-Pak), an S corporation
engaged in the packaging business. During the tax years at
issue, petitioner was the sole shareholder of Tek-Pak. As of
October 31, 1990, Goshorn's books and records reflected that the
"amount receivable" from Tek-Pak had been reduced by $104,213, to
$21,913. As of September 30, 1991, Goshorn's books and records
reflected that the "amount receivable" from Tek-Pak had been
reduced to zero.
Second, Goshorn recorded a transfer to petitioner per-
sonally, in the amount of $147,776.01. Petitioner was credited
first $60,000 was a credit for the $5,000 monthly rent due
petitioner from Goshorn. The remaining $108,124 consisted of
three transfers from petitioner's wife, Tangaree Weigel, to
Goshorn.
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