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Petitioners each received 5,000 shares of the common stock of
K&C, representing a 50-percent ownership interest in K&C for each
petitioner.
From 1984 through 1987, petitioners transferred to K&C an
additional $38,538 in small cash denominations from their
personal funds and $94,000 obtained from petitioner's father.
The following schedule reflects for 1984 through 1987 the
above funds transferred to K&C:
Funds Obtained Funds Obtained From
Year From Petitioners Petitioner’s Father
1984 $11,740 $17,500
1985 22,748 29,000
1986 4,050 44,000
1987 -- 3,500
Total $38,538 $94,000 $132,538
During 1984, 1985, and 1986, petitioners received from K&C
documents designated as promissory notes in favor of petitioners,
as follows:
Date Of Promissory Note Amount
July 23, 1984 $ 7,341
July 23, 1984 7,341
Mar. 21, 1985 85,000
Feb. 12, 1986 30,000
Total $129,682
On August 5, 1986, 40,000 shares of K&C stock were issued in
the name of petitioner's father and provided to petitioner’s
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