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financial decisions of Springbrook. His responsibilities
included signing checks, hiring employees, and establishing new
markets for the Dura-Craft kits. David Christie controlled all
of the financial decisions of Dura-Craft. His responsibilities
included signing checks, hiring employees, and making all major
decisions concerning production and new kit designs. Office
management and bookkeeping for both Dura-Craft and Springbrook
were performed at the office of Dura-Craft by employees of Dura-
Craft.
A. Loans
On February 10, 1983, the Chapmans and the Christies each
requested a loan in the amount of $37,500 from the Dura-Craft
Profit-Sharing Plan (Plan) to meet unspecified "emergency
financial requirements". On February 22, 1983, the Chapmans and
the Christies each signed separate notes agreeing to pay $37,500
to the Plan, plus 12 percent interest, accruing from February 22,
1983, until the principal was paid. On April 22, 1983, the Plan
agreed to lend $37,500 to the Chapmans and $37,500 to the
Christies at 12 percent interest, with a repayment date of
December 31, 1984 (collectively hereinafter referred to as plan
loans).2
2Nothing in the record indicates how to reconcile the fact
that the date that the Plan agreed to make the loans was after
the date that the individual petitioners signed separate notes
agreeing to repay the loans. We do not know whether this
discrepancy is the result of inadvertence or was intentional.
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