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increase in shareholder loans of approximately $123,000, while
the 1987 corporate income tax return reports a decrease in those
loans of $125,000.5 The record does not suggest that any
transactions other than the ones in issue could have affected
those figures. Moreover, petitioner testified that he accepted a
sum approximating the amount he had paid on Associates' behalf in
settlement of his "loan". Petitioner may therefore have received
only the distribution to which the parties have stipulated while
Associates may have treated the full amount of the "loan" as
having been discharged for reporting purposes regardless of any
discrepancy between the two amounts.
Accordingly, we find that petitioner received only
$117,164.91 from Associates during 1988.
To reflect the foregoing,
Decision will be entered
under Rule 155.
5 Respondent notes that the 1987 corporate return may reflect
payments made during calendar year 1987 as well as the
distribution that occurred during 1988 because Associates used a
tax year ending Sept. 30, 1988. However, any distribution that
petitioner might have received during 1987 would not be taxable
to him for 1988, the year in issue. Petitioner, moreover,
testified that he received no distributions from the corporation
prior to 1988.
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