Allen C. Chamberlin and Martha L. Chamberlin - Page 13

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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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