Daniel J. Culnen - Page 7




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          Wedgewood’s Income Tax Returns                                              
               Wedgewood’s Federal income tax returns for 1987 through 1990           
          show the following balance sheet entries with respect to loans              
          from shareholders:                                                          
               Year           Beginning Balance        Ending Balance                 
               1987           $186,827                 $1,773,887                     
               1988           1,773,887                3,530,306                      
               1989           3,530,306                4,380,992                      
               1990           4,380,992                6,097,200                      
               Wedgewood’s Federal income tax return for 1990 (the 1990               
          return) includes a Form 4797, Sale of Business Property, which              
          shows a disposition of furniture and fixtures acquired on                   
          April 1, 1988, at a cost of $2,780,959, and disposed of on                  
          September 1, 1990.  There is no gross sales price shown, and a              
          loss is claimed in the amount of $2,506,244, which is the                   
          acquisition price less depreciation (the difference being                   
          Wedgewood’s adjusted basis in the property).  Taking into account           
          certain other entries on the Form 4797, the net loss reported on            
          that form is $2,410,941 (the Form 4797 loss).  A Schedule K-1,              
          Shareholder’s Share of Income, Credits, Deductions, Etc.,                   
          accompanying the 1990 return, reports that petitioner’s share of            
          the Form 4797 loss is $1,759,987.                                           
          Culnen & Hamilton’s Income Tax Returns                                      
          Culnen & Hamilton’s Federal income tax returns for 1987 through             
          1989 show the following balance sheet entries with respect to               
          loans to stockholders:                                                      





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