Larry D. Johnson - Page 6




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          received from JCC into his personal bank account.  JCC booked the           
          transferred amount as an amount payable from petitioner.  At the            
          time petitioner received the transferred amount JCC was insolvent           
          and had not filed its U.S. Corporation Income Tax Returns for its           
          fiscal tax years ended June 30, 1986, 1987, and 1989,                       
          respectively.                                                               
               Although petitioner was aware that JCC was insolvent, he               
          believed that JCC’s net operating losses would result in no                 
          Federal tax liability for JCC.  It was usual for petitioner to              
          advance or loan funds to JCC and/or its subsidiaries.  Prior to             
          receiving the $286,737.27 from JCC, there had been regular                  
          advances and repayments of funds between JCC and petitioner.                
          Petitioner’s Income Tax Returns                                             
               On his 1991 Form 1040, U.S. Individual Income Tax Return,              
          petitioner reported interest income from the Johnson Corp., in              
          the amount of $25,924.  That amount represented interest on                 
          obligations owed to him by the Johnson Corp.  On his 1992                   
          individual Federal income tax return, petitioner also reported              
          wages from JCC’s subsidiaries (the Johnson Corp. and Heritage               
          Development Co.) in the amounts of $50,000 and $56,250,                     
          respectively.  Petitioner’s reported income of $304,637 did not             
          include the $286,737.27 received from JCC.                                  
          Tax Liability of JCC                                                        
               JCC’s corporate income tax return, for its fiscal tax year             






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