- 7 - under which petitioner served as the disbursing agent for them.7 As such, petitioner maintained approximately five or six bank accounts on behalf of those corporations, including an investment account, a payroll account, and other disbursement accounts. The Braswell sales corporations for which petitioner served as the disbursing agent deposited certain funds into the payroll and other disbursement bank accounts that petitioner maintained on their behalf. Thereafter, petitioner disbursed those funds on behalf of those corporations in order to make payments, inter alia, for the respective payroll and other liabilities and debts that those corporations incurred. Petitioner’s disbursements of funds on behalf of those corporations included disbursements of funds that were payable to CMC under the Vita-CMC agreement. In return for the services that it provided to the Braswell sales corporations over a period of time not established by the record herein, petitioner received an administrative fee from those corporations. That administrative fee, which was the source of most of petitioner’s income during that period, was calculated on the basis of a formula which, although not specifi- cally described in the record in this case, took into account the services that petitioner provided to each of the Braswell sales corporations and the volume of business that each of those 7It is not clear from the record whether other Braswell companies used petitioner as a disbursing agent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011