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suggesting that during the month of March 1996, there was
transferred from Blackland to petitioner $600,000. Any such
transfer apparently would have occurred under the above March 10,
1995, resolution in favor of petitioner and petitioner’s wife
with regard to their control of the funds of Blackland.
In April of 1996, those tenant farmers who had filed for
bankruptcy entered into settlement agreements with Blackland
under which Blackland agreed to release the tenant farmers from
all liability to Blackland on the farm loans in return for an
assignment from the tenant farmers to Blackland of all rights to
crop proceeds, crop insurance payments, and Government payments.
The trial record does not disclose the amount of funds that
Blackland and/or petitioner recovered under the above assignments
by the farmers of their crop proceeds, crop insurance payments,
and Government payments. From April 1, 1996 through December 1,
1996, however, Blackland’s monthly balance sheets reflect that
Blackland received approximately $350,000 in loan repayments from
the tenant farmers.
Beginning with Blackland’s June 30, 1996, balance sheet,
Blackland’s balance sheets make no further reference to a
$600,000 note receivable obligation due from petitioner to
Blackland, and yet there is no indication that petitioner made
such a payment to Blackland.
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