Daniel J. Culnen - Page 15




                                       - 15 -                                         



          Although Culnen & Hamilton was an S corporation only until                  
          May 31, 1987, Mr. Levin’s testimony presents a credible                     
          explanation of petitioner’s relationship with Culnen & Hamilton.            
               Janet Sacklow is a partner in the accounting firm of                   
          Amsterdam, Sacklow & Acox.  That firm also did accounting work              
          for Culnen & Hamilton, including preparing various financial                
          records and its income tax returns for the years in question.               
          Ms. Sacklow testified that she treated the Wedgewood payments as            
          loans to petitioner for purposes of both Culnen & Hamilton’s                
          books and records and its income tax returns.  She testified that           
          the initial record of the Wedgewood payments was made by Culnen &           
          Hamilton’s bookkeeper, Beatrice, who would record the Wedgewood             
          payments on the corporation’s general ledger under the heading              
          “Wedgewood” (the Wedgewood entries).  Beatrice made the Wedgewood           
          entries monthly.  Ms. Sacklow testified that she was responsible            
          for classifying the Wedgewood entries as loans to petitioner.               
          She testified that she made that determination based on                     
          conversations with petitioner and because she believed that                 
          Culnen & Hamilton had no association with Wedgewood:  “It was               
          only because of Dan Culnen that the money was coming from that              
          location [i.e., from Culnen & Hamilton].”  The parties have                 
          stipulated a letter dated February 11, 1993, from Ms. Sacklow               







Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  Next

Last modified: May 25, 2011