- 10 -                                         
          1998                                                                        
               During 1998, Paulan wrote four checks to Sidal as follows:             
                     Jan. 20               $100,000                                   
                       Feb. 17             200,000                                    
                    Aug. 25                18,000                                     
                     Oct. 27               650,000                                    
                        Total              968,000                                    
          The source of those payments was the $1 million Merchants Bank              
          loan.                                                                       
               Sidal’s adjusted trial balances for the taxable years ending           
          December 31, 1998, 1999, and 2000, reflect a note payable to                
          Paulan in the sum of $928,000,10 and Paulan’s adjusted trial                
          balance for the taxable year ending December 31, 1998, reflects a           
          corresponding note receivable from Sidal.  No adjusting entries             
          were made on those trial balances to recharacterize Paulan’s 1998           
          payments to Sidal, to the extent of $928,000, as Paulan’s loans             
          to petitioners and petitioners’ loans to Sidal.11  Handwritten              
               10  There is no explanation in the record for the                      
          discrepancy between the total amount of the 1998 Paulan checks,             
          $968,000, and the $928,000 note payable from Sidal to Paulan                
          reflected on Sidal’s adjusted trial balances.                               
               11  Although (1) a handwritten entry on Sidal’s adjusted               
          trial balance for its taxable year ending Dec. 31, 1999,                    
          indicates that the $928,000 note payable to Paulan was “reclassed           
          by AJEs” (adjusting journal entries) and (2) Sidal’s general                
          ledger for 1999 reflects the elimination, on Oct. 19, 1999, of              
          $928,000 as an intercompany note to Paulan, Sidal’s adjusted                
          trial balance for the following year (2000) still reflects the              
          $928,000 as a note payable to Paulan as of Dec. 31, 2000.                   
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