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OPINION
At the outset, we note that there is a discrepancy
involving the amount of the adjustment at issue. The
stipulation of facts filed by the parties states:
17. During the calendar year 1987, Whelpley
Associates, Inc[.], received at least
$103,693.00 from Weeden Capital Management,
Inc., which Whelpley Associates, Inc.,
included in gross receipts.
The parties also base their arguments on the assumption
that the adjustment at issue is $103,693, and the
stipulation of settled issues filed by the parties in the
related cases refers to $103,693. However, documents
entered into evidence including Mr. Flaherty's letter of
December 31, 1987, Weeden's general ledger trial balance
for 1987 and 1988, and Weeden's 1988 income tax return,
report the amount of the advances as $103,093. The parties
have not explained the discrepancy between these figures,
and we accept the stipulation of the parties on this point.
Character of Payments From Weeden to WAI
The principal issue in these cases involves the
characterization of the cash advances made by Weeden.
Respondent determined that the subject payments constitute
gross income to WAI in 1987 as reported on WAI's 1987
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