-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.Page: Previous 194 195 196 197 198 199 200 201 202 203 204 205 206 207 208 209 210 211 212 213 Next
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