- 3 - A. Petitioners Petitioners Richard J. Salem (Mr. Salem) and Eileen L. Salem (Mrs. Salem) are married and resided in Tampa, Florida, when they filed their petition in this case. Mr. and Mrs. Salem are hereinafter sometimes referred to as the Salems. Petitioners Robert S. Saxon (Mr. Saxon) and Bernice S. Saxon (Mrs. Saxon) are married and resided in Clearwater, Florida, when they filed their petition in this case. Mr. and Mrs. Saxon are hereinafter sometimes referred to as the Saxons. B. Salem, Saxon & Nielsen, P.A. 1. Background Mr. Salem and Mrs. Saxon are attorneys who are shareholders in the law firm of Salem, Saxon & Nielsen, P.A. (SS&N). During the taxable year 1990, Mr. Salem owned 450 shares of the stock of SS&N, and Mrs. Saxon owned 50 shares. Their general law practice is business oriented and includes litigation. Mr. Salem was admitted to practice before this Court in 1975. During the mid-1980's, SS&N began borrowing money from the Bank of Tampa (the bank). From 1987 through 1990, the bank made loans to SS&N on the following dates in the amounts indicated:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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