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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 controlled
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