- 24 -                                         
               In 1994, ERG paid $13,500 to MVPC and $2,000 to Camp                   
          Timberwolf.  On their personal return, the Bensons claimed a                
          charitable contribution deduction of $33,374, which included                
          $2,000 to Camp Timberwolf and $18,000 to MVPC.  ERG’s 1995 Form             
          1120 reflected charitable contribution carryovers of $102,646               
          from 1991, $13,200 from 1992, $1,984 from 1993, and $20,000 from            
          1994.  The $20,000 shown as a carryover from 1994 included a                
          $10,000 contribution to MVPC and a $2,000 contribution to Boy               
          Scouts of America (Timberwolf).                                             
               (i) Rent Paid to NPI for Stanford and Lowell Plants                    
               Throughout 1988-94, ERG occupied the Stanford plant which              
          was owned by NPI.  In 1988, a commercial lease for the Stanford             
          plant was prepared but not executed.  Similarly, in 1988, a                 
          commercial lease for the Lowell plant was prepared but not                  
          executed.  The Lowell plant was used by Glendon/Aker.25  During             
          the period 1988-94, ERG paid monthly rent to NPI for both the               
          Stanford and Lowell plants.26  The parties stipulated that the              
               25Glendon testified that he did not pay rent to NPI during             
          the period July 1987 through December 1994.                                 
               26Burton testified that before the arbitrators’ final                  
          decision in March 1999, he considered it ERG’s responsibility to            
          pay the rent for ERG’s research and development division, Aker              
          Industries.  In the final arbitration decision, the arbitrators             
          decided that Glendon/Aker was liable to NPI for rent for the                
          period July 1, 1987, through Dec. 31, 1998, in an amount                    
          including interest, totaling $420,650.                                      
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