Cordes Finance Corporation - Page 10

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                      Sometime after respondent's agent brought the above-                               
                omitted amounts and certain disallowed deductions to                                     
                Mr. Cordes' attention during the audit, petitioner filed                                 
                Form 1120X, Amended U.S. Corporation Income Tax Return,                                  
                with the Internal Revenue Service Center, Austin, Texas.                                 
                On that return, petitioner reported additional gross                                     
                receipts in the aggregate amount of $425,955, composed                                   
                of the following items:                                                                  

                      Deposits to account No. 312                $179,005.00                             
                      Late charges & collection fees             56,712.00                               
                      Bankruptcy collections                     15,745.15                               
                      American Express payments                  168,854.36                              
                      Martin's Restaurant payments               5,638.94                                
                      Total                                      425,955.45                              

                      The above items designated as payments to American                                 
                Express and Martin's Restaurant are payments for personal                                
                expenses of Edmund J. Cordes and his family that were                                    
                deducted on petitioner's 1990 return as "Repossession                                    
                Costs".                                                                                  
                      Petitioner's amended return for 1990 claims a loss                                 
                in the amount of $336,912 to offset the additional                                       
                income reported on the return, and it makes reference to                                 
                an adding machine tape to explain the nature of the loss.                                
                In substance, the adding machine tape states as                                          
                follows:                                                                                 
                      Cordes Finance Corp.                                                               
                      12-31-90                                                                           



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