-65- performed services for clients similar to those which TACI had provided to TACI’s clients. For a short period in 1989, PSAC also established two accounts similar to the TACI Special E Account and the TACI Special Account. The fees PSAC received from its clients were not sufficient to fund PSAC’s operations. From the time PSAC came into existence in 1989 until the time Gallenberger purchased the stock of PSAC from the ARO Trust in 1990, PSAC borrowed over $100,000 from BWK and THC to pay its employees’ salaries. Gallenberger, Transcr. at 1980-1982, 1987, 2041. BWK lent the money to PSAC either directly or through the TACI Special E Account. Gallenberger, Transcr. at 1983-1984. Beyond 1990, PSAC did not generate enough fees to cover its operational costs, continued to operate at a loss, and borrowed money from BWK. Gallenberger, Transcr. at 1985-1986. At the time the record in these cases was closed, PSAC had not repaid the loans from BWK. Id. When borrowing money, Gallenberger either contacted Kanter about the loan or went ahead and borrowed the money herself. Gallenberger, Transcr. at 1986-1987. PSAC’s bookkeeping procedures and return preparation procedures were essentially the same as TACI’s. Gallenberger, Transcr. at 1988-1989, 2078. Any questions that Gallenberger hadPage: Previous 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 Next
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