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to Walter J. Pagano, c.P.A. (the Sacklow letter).9 The Sacklow
letter states: “Enclosed are the schedules of amounts loaned to
Wedgewood Associates and Dan’s acquisition costs for stock and
partnership interests.” Ms. Sacklow testified that she prepared
those schedules (the schedules) from the books and records of
Culnen & Hamilton. The first of the schedules relates to the 46
checks and states that they were “deposited into Wedgewood
Associates accounts, on behalf of Daniel Culnen.” The third of
the schedules relates to the six checks and states: “Daniel
Culnen’s purchase of Dr. Nagle’s Interest”. The final page of
the schedules states:
Summary
Net Checks Written to Wedgewood from
Culnen and Hamilton $3,659,017.41
Checks written from Culnen and
Hamilton on behalf of Wedgewood 501,918.22
Dan’s purchase of Dr. Nagle’s interest 568,152.17
Other Items 737,733.27
Interest Accrued 616,070.49
Total $6,082,891.56
Of this total, $300,000 is classified as Capital Stock
in Wedgewood Associates, and $300,000 is Dan’s cost of
purchasing Manning’s partnership interest. $568,152.17
is Dan’s cost for Nagle’s interest in stock and
partnership. This leaves a balance of $4,914,739.39 as
a loan to the corporation.
9 By the stipulation, respondent reserved the right to
make a relevance objection to the Sacklow letter, but respondent
waived all other evidentiary objections, including an objection
based on hearsay. See Fed. R. Evid. 802.
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