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resulted in (1) sales commissions to that S corporation of an
unspecified amount that was less than $87,2493 and (2) approxi-
mately $2.5 million of gross sales to Westchem.
During approximately the second half of 1999, Mr. Hopkins’s
S Corporation made certain expenditures totaling $16,501 (Mr.
Hopkins’s S Corporation’s expenditures of $16,501) that consisted
of loan payments of $9,609 with respect to Mr. Hopkins’s motor
home, certain unidentified automobile racing expenditures of
$6,620 (Mr. Hopkins’s S Corporation’s unidentified automobile
racing expenditures of $6,620), and certain advertising (hats)
expenditures of $282.4 During the same period, Mr. Hopkins’s S
Corporation made certain additional expenditures totaling $39,557
(Mr. Hopkins’s S Corporation’s expenditures of $39,557) that
consisted of sponsorship payments of $39,000 to race car driver
Davey Hamilton (sponsorship payments to Mr. Hamilton of $39,000)
and payments of $557 for country club dues (country club dues
payments of $557). Sponsorship payments to a race car driver,
3As discussed below, Mr. Hopkins’s S Corporation reported
that during 1999 it had $87,249 of gross receipts (i.e., sales
commissions). Westchem was not the only customer of Mr.
Hopkins’s S Corporation, and the record does not disclose the
amount of gross receipts (i.e., sales commissions) that Mr.
Hopkins’s S Corporation received from its other customers.
4The parties stipulated that Mr. Hopkins’s S Corporation’s
expenditures of $16,501 consisted of the amounts set forth above.
However, those amounts total $16,511. There is no explanation in
the record for this discrepancy. We shall use the total amount
stipulated by the parties.
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