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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:
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