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Petitioner claims that he contributed or reloaned the entire
amount of proceeds to The Chamberlin Corp. and Chamberlin
Parenteral. Respondent argues that only $450,000 of the
principal was reloaned to these corporations. Second,
petitioners argue that they are entitled to losses stemming from
funds that petitioner contributed to The Chamberlin Corp., which
were used for operating capital and the initial purchase of the
Pharmacare assets in 1981.
Of the principal amount of the Freedom Federal loan,
$450,000 was reloaned to The Chamberlin Corp. and used to repay a
portion of a debt owed by The Chamberlin Corp. to E.F. Hutton
Credit Corporation. Petitioner testified at trial that the
remaining $1,300,000 of the Freedom Federal loan was used to
purchase Bel-Mar, which later became Chamberlin Parenteral, and
to provide working capital or to pay debts of The Chamberlin
Corp. Petitioner also testified that he contributed all of the
funds used by The Chamberlin Corp. to buy the assets of
Pharmacare from the trustee in bankruptcy in 1981.
Petitioner has failed to provide sufficient evidence showing
that the $1,300,000 of remaining principal was reloaned or
contributed to either corporation or to show how much funding, if
any, he provided to The Chamberlin Corp. for the asset purchases
or startup costs. There is no contemporaneous corroboration of
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