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check payable to petitioner. After receiving the initial check,
petitioner requested that Mr. Kapusta issue the remaining
reimbursement checks payable to Clairol, which was a supplier of
beauty products. The payments made by Mr. Kapusta to reimburse
petitioner and Ms. McNamara for the renovations to the beauty
shop were as follows:
Check No. Date Amount Payee Description
1170 3/11/89 $500 Petitioner First
installment
1241 5/26/89 3,000 Clairol * * * products
1354 Aug. 1989 1,500 Clairol Supplies
1402 Sept. 1989 2,500 Clairol --
1247 11/22/89 2,000 Clairol Supplies
1509 12/20/89 2,000 Clairol Supplies
1551 1/24/90 2,000 Clairol Supplies
1589 2/22/90 2,000 Clairol Supplies
1620 Mar. 1990 2,000 Clairol Supplies
1839 9/18/90 6,000 Clairol Supplies
1883 Oct. 1990 2,000 Clairol Supplies
1933 Dec. 1990 2,000 Clairol Supplies
The proceeds from these checks issued to petitioner or
Clairol were deposited in petitioner and Ms. McNamara’s personal
joint checking account at Continental Bank. The proceeds from
these checks were not recorded as income on the corporation’s
books and records or reported as income on any of the
corporation’s, or of petitioner and Ms. McNamara’s, Federal
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