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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.
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