Daniel F. Nix and Gayle H. Nix - Page 4




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               With regard to petitioners’ funds that were used to pay                
          expenses of Telim, no promissory notes were issued by Telim to              
          petitioners, and no repayments were made by Telim to petitioners.           
               As of the end of 1987, as a result of the defective                    
          telephones and lack of profits, Telim’s business operations were            
          effectively terminated.  On January 1, 1988, a Telim corporate              
          resolution authorized Amos to sell Telim's capital equipment in             
          Taiwan and to pay off Telim's debts in Taiwan.  Petitioners were            
          authorized to sell Telim's assets located in the United States in           
          order to pay off Telim's remaining debts.  The Telim shares of              
          stock owned by Morales and Amos were transferred to petitioners             
          in exchange for releases of Morales and Amos from any debt                  
          obligations of Telim.                                                       
               On January 1, 1988, Morales and Amos resigned as officers of           
          Telim.                                                                      
               On October 11, 1991, petitioners sold for a gain of $26,713            
          their personal residence in Novato, California, and petitioners             
          moved to Austin, Texas.  Petitioner's employer paid $18,419 of              
          petitioners' moving expenses to Texas.  Petitioners built a new             
          residence in Austin that was completed in March of 1994, at which           
          time petitioners moved into the new residence.                              
               Telim’s 1987 corporate Federal income tax return reflected a           
          total of $16,623 as loans to shareholders.                                  







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