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Payee 1989 1990 1991 1992 1993
John Cordes $108,000 $54,000 $84,000 $20,000 $30,000
Mrs. Cordes1 120,000 120,000 135,711 150,000 220,000
Jean Ann Richard 24,000 24,000 4,000 -0- -0-
Ellen Cordes2 12,000 15,500 1,500 -0- -0-
Jean Patton 18,000 18,000 1,500 -0- -0-
Mr. Cordes 10,700 47,159 323,200 -0- -0-
Ray Lee 18,000 12,000 -0- -0- -0-
Margie Lange 5,000 -0- -0- -0- -0-
Cordes bank accts. -0- -0- 50,600 -0- -0-
John Cordes, Inc. -0- -0- 300,000 -0- -0-
Total 315,700 290,659 900,511 170,000 250,000
1Mrs. Cordes conceded that the funds distributed to her
constitute income from constructive dividends as determined by
respondent. See Appendix B, Summary of Conceded, Deemed
Conceded, Computational, and Settled Issues. Because Mrs.
Cordes’s concession is inconsistent with the substance of her
argument and in light of our holding regarding the beneficial
ownership of the Cordes corporations, we relieve her of her
concession and conclude only that these are constructive
dividends to Mr. Cordes in 1992 and 1993.
2Ellen Cordes is Mr. Cordes’s daughter-in-law; Jean Patton
is Mr. Cordes’s sister; Ray Lee and Margie Lange are Mr. Cordes’s
friends. Also, the Cordes bank accounts are personal accounts
jointly held by Mr. and Mrs. Cordes. During 1991, Mr. Cordes and
John Cordes were the sole holders of legal title in John Cordes,
Inc. See Appendix A, Schedule of Stock Transfers, for details of
their proportionate holdings.
C. Corporate Payments of Personal Expenses
In 1989, 1990, and 1991, Mr. Cordes caused CFC to pay
certain of the Cordes family’s personal expenses, as follows:
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