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keep WIS afloat. During 1990 petitioner provided additional
capital, both through contributions and loans. In January 1990
petitioner made two deposits totaling $29,000 into the WIS
payroll account maintained at the Citizens & Southern National
Bank. On February 28, petitioner executed a promissory note and
security agreement in favor of Navy Federal Credit Union in
exchange for a personal loan of $14,000. He then deposited the
loan proceeds into the WIS account at Palmetto Federal. The
deposit slip identifies the amount deposited as “Loan”. On
March 1 petitioner entered into a sale-leaseback agreement with
Palmetto Rental & Leasing, Inc. (PR&L), with respect to five
motor vehicles. PR&L purchased the vehicles and agreed to lease
them to WIS for a stated term. All proceeds of the sale were
deposited into WIS’s account at Palmetto Federal on March 5. The
proceeds attributable to each vehicle were as follow:
Ford Aerostar $3,330
Toyota Pickup 2,050
Toyota Pickup 4,800
Toyota Cressida 4,000
Ford Bronco 8,000
22,180
For each vehicle except the Ford Aerostar, an Affidavit &
Notification of Sale of Motor Vehicle identifies the seller as
either petitioner alone or petitioners jointly. In the case of
the Ford Aerostar, the seller is listed as “WMS Invest Sec & T.
Williams”. In each case the seller(s) correspond to the owner(s)
identified on the vehicle’s Certificate of Title.
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Last modified: May 25, 2011