- 266 - between entities with no documentation to establish a rationale for such transfers. He created phony loans that were eventually written off, and then he or the corporations took bad debt deductions to offset additional income. Similarly, Lisle, Ballard, and Kanter failed to recognize any separate identity of Carlco, TMT, and BWK, Inc. Petitioners assert that Lisle, Ballard, and Kanter were only the respective managers of the assets of Carlco, TMT, and BWK, Inc., and claim that the preferred stock issued to their family trusts had minimal value. The record clearly shows, however, that petitioners' control over the assets of the corporations went far beyond that of a manager. Petitioners used the funds for their personal benefit. From 1984 to 1986, Ballard transferred $16,599 to himself that was recorded as a receivable on TMT's books. In 1987, Ballard transferred the St. Francis Arkansas land owned by TMT to himself and recorded the transfer as a sale. He did not pay for the land but recorded a receivable of $100,000 as owed by him on TMT's books. In 1987, TMT funds also were used to pay $20,344 to the Fairfield Plantation Company, Ballard's S corporation. The payment was recorded as a receivable owed by Ballard. In 1989, Ballard distributed $10,000 to himself from TMT and increased his receivable to $146,943. In addition, Ballard distributed $160,000 of TMT's funds to his wife, $122,900 to the SeabrightPage: Previous 256 257 258 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 Next
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