- 32 - controlling facts would be dismissed in the same manner that similar contentions of petitioners regarding the Aldergrove issue were dismissed, see supra sec. II.C.4.c. In conclusion, petitioners are precluded from denying that, on February 26, 1987, and December 22, 1988, petitioner controlled Aldergrove partnership matters and benefited from and controlled the funds held by Aldergrove. f. Are the 1991 Interest Payments Taxable to Petitioners? Promissory notes in evidence indicate that petitioner loaned the following amounts to Chestnut Grove and Group M, and we so find: Date Maker Amount March 1, 1987 Chestnut Grove $23,382 March 1, 1987 Group M 176,618 March 1, 1988 Group M 110,000 January 19, 1989 Group M 200,000 Petitioners present numerous documents and other evidence to explain the fate of the first three of those notes and to support their assertion that the Yakima interest payments represent interest paid to Mr. Bell. The findings, however, that, on February 26, 1987, and December 22, 1988, petitioner controlled Aldergrove partnership matters and benefited from and controlledPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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