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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.
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