- 32 - about July 29, 1994, accountant Bradac sent Burton a letter which stated in part: Loans to Stockholders cannot be identified from our workpapers. If it could be identified, any amounts due from stockholders should be shown here, and the Corporation should make sincere efforts to collect. Any stockholder who has not repaid a corporate loan has personal income to report if the loan is forgiven by the Corporation. On October 25, 1995, the Bensons filed their 1994 return. 4. Transfers From NPI In 1993, Burton caused NPI to issue: (1) Check Nos. 424, 439, and 444, totaling $129,480 from NPI’s bank account made payable to the California Franchise Tax Board to pay his personal tax liabilities; and (2) check Nos. 423, 425, 432, and 438 from NPI’s bank account made payable to the Internal Revenue Service (IRS) to pay his personal tax liabilities, the aggregate amount of which was $378,000.39 In 1994, Burton caused NPI to: (1) Issue check Nos. 452, 462, and 468 totaling $28,745 from NPI’s bank account made payable to the California Franchise Tax Board to pay his personal tax liabilities; (2) issue check Nos. 446, 451, 455, and 461 39The parties stipulated that check No. 424 for $81,000 and check No. 444 for $28,480 totaled $129,480, which was obviously an error since these two sums equal $109,480. It is clear from the documentary evidence in the record that three checks, Nos. 424, 439, and 444 were written from NPI’s bank account to the California Franchise Tax Board in the total amount of $129,480. Additionally, it is clear from the evidence that NPI issued checks, Nos. 423, 425, 432, and 438 to the IRS in the total amount of $378,000.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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