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Petitioner used FCE funds to partially pay for the
construction of his personal residence. In particular, FCE paid
First Coast Supply between $8,000 and $10,000 to build and
install kitchen cabinets in petitioner's new home.
In late 1989, or early 1990, petitioner and Mr. Young had a
falling out, and FCE ceased operations by early 1990. Upon the
closing of FCE, the company's computer and copier were stored at
the apartment of Ms. Fischer until they were given to petitioner.
Income From Paragon Construction Group, Inc.
On April 4, 1990, petitioner incorporated PCG, which
operated as a general contractor in the construction business.
Petitioner was the sole shareholder and president of this
corporation. Petitioner started PCG with a capital contribution
of $20,000. PCG had a corporate bank account at First Union
National Bank of Florida. Petitioner had complete control over
this account. Checks written on PCG's corporate account directly
to petitioner totaled $39,219.91 in 1990 and $82,162.80 in 1991.
In addition to the checks written directly to petitioner,
PCG also paid for labor, materials, building permits, and
property taxes associated with the construction of petitioner's
personal residence, including the following:
Check No. Date Payee Amount
107 4/20/90 Coastal Interiors $2,200.00
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