- 9 - A. GITIC General Payment date Lender Amount ledger acct. 2/22/95 GITIC $102,222.22 Interest paid 8/23/95 GITIC 74,788.19 Interest paid 177,010.41 2/23/96 GITIC 70,916.67 Interest paid 8/23/96 GITIC 68,881.94 Interest paid 1139,798.61 1Petitioner also paid $65,000 by wire transfer to or for the benefit of GITIC on May 29, 1996, and contends that the payment was an interest payment. However, it does not appear from the record as a whole that petitioner included this payment in computing the amount identified in the Sept. 8, 1998, letter or in its 1996 Form 5472, nor does it appear that respondent included this amount in calculating the 1996 deficiency. Consequently, we do not consider this payment in our analysis. B. GXE General Payment date Payee Amount ledger acct. 3/31/95 GXE 1$33,475.15 From EB MMA 3/31/95 GXE 248,228.68 Interest paid 9/21/95 GXE 83,058.25 Interest paid 164,762.08 3/21/96 GXE 77,099.91 Interest paid 1The last digit of this entry does not appear on the exhibit, but we infer that it must be as reflected above because petitioner apparently included this amount in calculating the total amount of interest paid on the GXE loan during 1995 as reflected in the Sept. 8, 1998, letter. 2We cannot tell from an examination of the general ledger whether the $33,475.15 payment is included in the $48,228.68 entry. However, because petitioner apparently treated it as a separate and additional interest payment and because the total coincides with the total interest amount in the Sept. 8, 1998, letter, we shall also treat the $33,374.15 payment recorded in the general ledger as a separate payment for purposes of our analysis.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: March 27, 2008