-204-
does not include loan documents or notes evidencing the loans to
Ballard, Lisle, and their grantor trusts.
At the end of 1987, IRA sold its IFI stock to Gallenberger
for $1. Exh. 5912, at 7 (AJE 6). In addition to receiving the
IFI stock, Gallenberger was given $3,000 identified as accounting
fees. Exh. 9020; Exh. 35, at 12. IRA claimed a long-term
capital loss of $65,000 attributable to this transaction on its
1987 tax return. Exh. 22, Schedule D.
In March 1989, approximately 2 years after IFI transferred
receivables of $1,120,889 to IRA, IFI filed for bankruptcy. Exh.
627. At the time of the bankruptcy filing, Gallenberger was
IFI’s vice president, and she owned 100 percent of its stock. At
the time of IFI’s bankruptcy, IFI owed debts to the following
creditors:
Creditor Reason Amount of Claims
IRS 1984 taxes $5,500
Kanter Legal services 750
Neal, Gerber
& Eisenberg Legal services 550
PSAC Services 700
I&F Corp. Services 775
Total 8,275
Exh. 627.
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