Michael P. and Pamela J. Hopkins - Page 5

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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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