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all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts, with attached exhibits, is incorporated
herein by this reference.
Residence
At the time of filing the petition, petitioners resided in
Wellington, Florida.
The Corporation
The corporation in question is Palm Beach Furniture Co.,
Inc., a Florida corporation (the corporation). The corporation
is a calendar-year taxpayer.
The Bank
Monroe Bank and Trust (the bank) is an institution whose
address is in Monroe, Michigan.
The Loan Agreement
By agreement dated October 28, 1994 (the loan agreement),
the bank agreed to lend the corporation $1.2 million (the loan).
Among other things, the loan agreement provides that the term of
the loan is 6 years, the interest rate is 8 percent, and
approximately $250,000 of principal will be repaid during the
loan term (leaving a principal balance of $947,835.50 to be paid
at maturity). The loan agreement also provides:
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Last modified: May 25, 2011