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issue, either to the Oklahoma Bank or to Christopher in
reimbursement for his payments.
B. Loan 92107 for $70,000
On January 27, 1995, petitioner shareholders and Cox Tomato
as co-makers borrowed $70,000 from the Oklahoma Bank (loan 92107)
for Cox Tomato’s operating capital. Petitioner shareholders and
Cox Tomato executed an installment note for $70,000 in favor of
the Oklahoma Bank. Christopher and Brenda also gave the Oklahoma
Bank a mortgage on their personal residence as security for the
loan.
Christopher treated loan 92107 as his personal obligation
and made at least some payments on it during 1995. Neither
Gregory nor Deborah made any payments on the loan, either to the
Oklahoma Bank or to Christopher in reimbursement for his
payments, during 1995.
III. Monthly Distributions and Corporate Automobile
Cox Tomato distributed to Deborah $1,500 each month from
January to May 1994, and from January to December 1995. In the
intervening months of June 1994 to December 1994, Cox Tomato
distributed to Deborah only $1,420 each month, retaining the $80
difference as Deborah’s payment for her personal use of a 1994
Ford Explorer (automobile) provided to her by Cox Tomato from
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Last modified: May 25, 2011