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Marc Pays $800,000 to Pleasant Prairie and Lakeview
Contemporaneously with the transactions described above,
Marc paid the $800,000 loan proceeds to Pleasant Prairie and
Lakeview. Specifically, on December 29, 1997, Marc issued
Lakeview a $550,000 check, which Lakeview deposited in its
account at the Bank. Also on December 29, 1997, Marc issued to
Pleasant Prairie a $250,000 check, which Pleasant Prairie
deposited in its account at the Bank. Prior to making this
payment, Marc had an account payable balance due to Pleasant
Prairie in the amount of $204,222.
Pleasant Prairie and Lakeview Pay Petitioner $800,000
On or before January 8, 1998, petitioner borrowed $550,000
from Lakeview and $250,000 from Pleasant Prairie.3 Petitioner
deposited the proceeds in his account at the Bank.
Petitioner Repays Bank $800,000
On January 8, 1998, petitioner paid off the note by issuing
the Bank a check in the amount of $800,000, drawn on his account
at the Bank.
3 The parties stipulated that petitioner borrowed the
$250,000 from Lakeview. On brief, however, the parties appear to
agree, consistent with other facts disclosed by the record, that
petitioner borrowed the $250,000 from Pleasant Prairie.
Accordingly, we decline to be bound by the apparently inadvertent
error in the stipulation. See Gulf Oil Corp. v. Commissioner, 87
T.C. 135, 159 n.4 (1986), affd. 914 F.2d 396 (3d Cir. 1990).
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Last modified: May 25, 2011