- 5 -
The $200,000 stock subscription was paid or otherwise
satisfied during 1986. On various dates during December 1986,
petitioner and Ihsan Dura deposited funds totaling $149,337.50
into the bank account of C & I at Central Fidelity Bank (C & I
bank account). The source of $23,800 of the amount so deposited
by petitioner was petitioner's mother, Gloria M. Wynn. During
1986, petitioner and Ihsan Dura also paid one of C & I's accounts
payable totaling $20,000 (C & I account payable).
Certain financial workpapers of C & I (C & I's financial
workpapers) dated as of December 31, 1986, recorded $149,337.50
of the deposits into the C & I bank account, $10,662.50 of the
$20,000 payment of C & I's account payable,4 and a loan receiv-
able of $40,000 as reductions of the $200,000 stock subscription.
On October 6, 1986,5 C & I offered to purchase the business
known as Linea Pitti for $175,000, of which $30,000 was allocable
to inventory and $145,000 was for the assumption of the lease of
the premises. That purchase offer was approved, and C & I began
operating Linea Pitti in late 1986.
After C & I began operating Linea Pitti in late 1986, it
employed petitioner and Ihsan Dura full-time and compensated them
4 C & I's financial workpapers recorded $9,337.50 of the
$20,000 payment of C & I's account payable in an account desig-
nated "Loan--officers" (officers' loan account).
5 The record does not disclose how C & I, which was not incor-
porated until Nov. 24, 1986, could have offered to purchase Linea
Pitti on Oct. 6, 1986. Presumably that offer was made in the
name of C & I in anticipation of its being incorporated.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011