William H. Breucher III - Page 7

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          did not require a repayment schedule for such “advances”.                   
          Bruecher Foundation did report the “advances” as a liability on             
          each of its Forms 1120, U.S. Corporation Income Tax Return,                 
          Schedule L, Balance Sheets per Books for the fiscal tax years               
          1998 and 1999.                                                              
               In the notice of deficiency issued to Mr. Bruecher,                    
          respondent determined that for tax years 1998 and 1999 he                   
          received constructive dividends in the amounts of $33,082 and               
          $48,112, respectively.  These amounts were computed by using                
          figures in the “Advance - Bruecher, WM.” account adjusted as                
          follows:                                                                    
          Tax Year 1998                                                               
               Date                                      Amount                       
               04/01/1998 - Beginning balance     $77,318                             
               12/31/1998 - Ending balance              120,325                       
               Difference - Increase in balance   43,007                              
               Corporate expenses paid by                                             
                    Mr. Bruecher1                       9,925                         
               Net constructive dividends         33,082                              


















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