- 17 - At no time did Mr. Whitehead make any payments to Mr. Stanford on the promissory note that Mr. Whitehead signed on September 13, 1991, in exchange for Mr. Whitehead’s purchase of all of Mr. Stanford’s Burien Nissan stock. As discussed above, Burien Nissan continued to make monthly payments of $2,000 to Mr. Stanford from April 1995 until at least September 1999. Neither Mr. Whitehead nor Burien Nissan expected Mr. Whitehead to repay those amounts to Burien Nissan. A document dated May 31, 1996, entitled “Burien Nissan, Inc. Adjusting Journal Entries for the period ended December 31, 1995",9 showed, inter alia, the following entries (AJE 15 en- tries) under the heading “AJE 15": Account # Account Name/Description Debits Credits 3440 Note Payable-Ken Stanford 178,000 3910 Retained Earnings 178,000 To record note payable on capital stock redeemed Petitioners’ Respective Uses of Certain Burien Nissan Automobiles During the years at issue, neither Mr. Whitehead nor Ms. Whitehead owned an automobile. During each of those years, each petitioner had the use of, and did use, certain automobiles owned by Burien Nissan (Burien Nissan automobiles). During the years at issue, petitioners did not pay Burien Nissan for their respec- tive uses of certain Burien Nissan automobiles. 9The record does not disclose who prepared that document.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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