Chen C. and Victoria R. Wang, et al. - Page 11

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          improved real estate.  In fact, EIC typically paid commissions              
          that were between 10-15 percent of the sales price.  During 1989,           
          on average, EIC paid commissions of 13 percent.                             
               Often, more than one agent would be involved with a particu-           
          lar sale.  In these cases, petitioner allocated the 13-percent              
          commission among the sales agents who participated in the sale,             
          based upon each agent's level of participation.  Petitioner is an           
          experienced sales agent, however, and many times he would be the            
          only person involved in a sale by EIC.  In those circumstances,             
          EIC paid the full 13-percent commission to petitioner alone.  For           
          1989, petitioner received $901,428 in commissions from EIC, and             
          EIC claimed a deduction for this amount.                                    
               During the years in issue, the financial relationship                  
          between petitioner and EIC was not limited to the compensation              
          paid to petitioner.  In fact, EIC's financial statements as of              
          December 31, 1989, disclose both "notes receivable" from peti-              
          tioner in the amount of $873,194 as well as "notes payable" to              
          petitioner in the amount of $1,010,895.  These amounts comport to           
          the figures reported in EIC's December 31, 1989, corporate income           
          tax return.  EIC maintained separate accounts in its general                
          ledger to track funds transferred to petitioner and funds                   
          received from petitioner.  As of December 31, 1990, the corporate           
          income tax return for EIC reported "Loans from Stockholders" of             
          $1,312,199 and "Loans to Stockholders" of $1,717,892.  The                  





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