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the FYE May 31, 1981-94,14 the composition of G�nther’s
intercompany account balances for the FYE May 31, 1991-94, the
amount of G�nther’s bank loans assumed by petitioner during FYE
May 31, 1994, and certain waivers of intercompany account
balances discussed, infra.
Balance Balance
owed owed by
by (to) Waivers (to)
Group G�nther of G�nther Bank
FiscalCorporateInterestexpense Interco. Cash before Interco. after debt
year charge charge allocationpurchasesadvanceswaivers balance waiversassumption
1981 --- --- --- --- --- $836,430 --- --- ---
1982 --- --- --- --- --- 1,476,550 --- --- ---
1983 --- --- --- --- --- 1,129,649 --- --- ---
1984 --- --- --- --- --- 747,695 --- --- ---
1985 --- --- --- --- --- 31,830 --- --- ---
1986 --- --- --- --- --- (9,787) --- --- ---
1987 --- --- --- --- --- (431,874) --- --- ---
1988 --- --- --- --- --- (104,906) --- --- ---
1989 --- --- --- --- --- 434,349 --- --- ---
1990 --- --- --- --- --- (91,019) --- --- ---
1991 $180,000 $36,992 $130,327 $341,436 $650,000 1,247,736 --- --- ---
1992 180,000 275,006 26,178 564,736 4,270,468 6,564,124 --- --- ---
1993 180,000 184,36651,792 --- 2,834,8239,815,105($9,000,000)$815,105 ---
1994 50,000 58,635 23,570 --- 2,243,5833,190,893(2,429,665)761,228$3,709,460
G�nther made no payments on its intercompany account balance
during FYE May 31, 1992, 1993, or 1994. Petitioner did not
expect advances it made to G�nther or on G�nther’s behalf during
FYE May 31, 1992, 1993, and 1994 to be repaid.
14The record does not reflect the specific charges before
FYE May 31, 1991.
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