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the taxpayer". Nevertheless, that is the thrust of their
argument.
The difficulty with petitioners' argument is that
there is no evidence that Weeden sought to make an equity
investment in WAI. To the contrary, Mr. Flaherty
testified, and we find, that Weeden did not have an
interest in becoming a stockholder of WAI and that
Weeden's management never considered investing in WAI's
stock. He further testified, and we find, that Weeden
intended to advance moneys to CPI, and if the CPI project
was successful, to receive an equity interest in CPI.
Mr. Flaherty testified as follows:
Q And what was your understanding, if
you can recall, of Weeden's investment or
involvement or what did it get as a result
of transferring these monies, if anything.
Did it have a right to be repaid, for
example?
* * * * * * *
The Witness: Well, a right to be
repaid? I guess we had a right to. I mean,
they were advances, I guess. I -- the way
-- I know what the intent was, if
that's what you're asking.
Q What was the intent, sir?
A The intent was that we would advance
monies to Cpi, Cpi would develop these
products, we would have -- get an equity
position eventually in Cpi and that's why
we were doing it.
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