- 15 - Petitioner recorded his transactions with each partnership on a ledger (the ledger). Respondent introduced into evidence a computer spreadsheet outlining those transactions, which utilized the ledger. Petitioner also recorded certain financial information concerning petitioner and the partnerships on several documents entitled "GAP loan interest payments" (GAP sheets). The GAP sheets purport to record short-term loans from petitioner to the partnerships. The amounts and dates of payment reflected on the GAP sheets are virtually identical to the entries listed on the ledgers. The only difference is the manner in which certain of the payments are recorded. On the GAP sheets, these payments are recorded as loans from petitioner to the partnerships. On the ledgers, they are recorded as miscellaneous draws from the partnerships. The ledgers do not reflect loans from petitioner to the partnerships in the amounts and on the dates indicated on the GAP sheets. Apart from the GAP sheets, there is no evidence in the record that petitioner lent money or otherwise transferred funds to the partnerships during the years at issue. Some of the ledgers reflect negative balances at the close of the year. The limited partnerships' offering circulars specifically state: "No loans of any type or description shall be made or given to the General Partner, its constituent partners or its affiliates". The offering circulars did permit petitioner, asPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011