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he was going to "fix" the letter. After being asked to sign June
2, 1987 I, Thorpe began to lose faith in petitioner.
June 2, 1987 II lists, separately, "Payments made by INI
Builders, Inc. on the $100,000 note for bonus", totaling $67,500,
and "Payments made by A. Lee Petersen, including credits for
services, on purchase of corporate stock" (emphasis added),
totaling $50,369.83. The second page of June 2, 1987 II bears
petitioner's signature and Thorpe's signature indicating
agreement with the figures, dated June 26, 1987. Thorpe did not
sign June 2, 1987 II. The signature pages of June 2, 1987 I and
June 2, 1987 II are one and the same; petitioner attached the
signature page of June 2, 1987 I to the first page of June 2,
1987 II.
Petitioner knew O’Meara would rely on Heirs III and June 2,
1987 II. O’Meara relied on Heirs III and June 2, 1987 II in
reaching the conclusion that the $100,000 bonus was fully
deductible. He would not have allowed the deduction without
having received these documents. O’Meara determined that no
additional tax was due from INI and issued a no-change letter
closing the appeal on July 21, 1987.
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