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1990 $213,900
1991 182,088
1992 164,447
1993 176,5032
1994 165,003
1995 166,410
1996 167,817
1The parties stipulated the amounts that HJA paid under the
covenant not to compete, and those amounts are summarized here.
The amounts listed for 1991, 1995, and 1996 differ from the
amounts shown on the relevant Forms 1099 and in the letters of
explanation. The amounts shown for 1994, 1995, and 1996 were
paid by HJA and deducted, but respondent has not yet disallowed
those deductions.
2In 1993, HJA made payments directly to FirsTier and
Chevrolet in the amount of $165,003. HJA also made a direct
payment to Henry in the amount of $3,000 and credited it as a
covenant not to compete payment. In 1993, Chevrolet made an
$8,500 payment on personal insurance for Henry and credited the
payment as a covenant not to compete payment.
Part of the covenant not to compete payments was applied to the
Chevrolet debt and the FirsTier note, either through the sweep
account or directly, as follows:
Year Chevrolet debt FirsTier note Total
1990 $38,361 $31,998 $70,359
1991 6,394 7,999 14,393
1992 76,721 87,726 164,447
1993 76,722 88,281 165,003
1994 76,721 88,282 165,003
1995 76,722 89,688 166,410
1996 76,721 91,096 167,817
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