Windsor Production Corporation - Page 3

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              Petitioner's shareholders and board of directors met on                 
          December 1, 1987.  The minutes of that meeting show that                    
          petitioner would probably need to plug 38 wells at a cost of                
          between $10,000 and $40,000 per well.  The minutes also show                
          that petitioner had begun negotiations to buy oil or gas projects           
          which required initial investments as follows:  $130,000 for                
          Kelso; $450,000 for Quail Creek; $375,000 for Boren; and $760,000           
          for Turkey Creek.  The board allocated $1 million to plug wells             
          and acquire new projects.                                                   
          2. Revenue Agent's Contacts with Petitioner's Representatives               
              Richard Saul (Saul), respondent's revenue agent assigned to             
          this case, worked closely with Leonard Hochheiser (Hochheiser),             
          petitioner's representative.  On October 5, 1989, Saul asked                
          Hochheiser for a copy of petitioner's tax returns for 1986 and              
          1987.  Hochheiser gave those returns to Saul on November 10,                
          1989.  On January 3, 1991, Saul asked Hochheiser to agree to                
          extend the time to assess tax for petitioner's 1987 year.  Saul             
          received a letter on February 4, 1991, in which Hochheiser                  
          declined.  On February 6, 1991, Saul met with Hochheiser and                
          discussed petitioner's business generally and the audit.  Saul              
          briefly mentioned section 531 as an issue to be considered.  He             
          did not ask petitioner's owners or Hochheiser whether petitioner            
          needed to accumulate earnings or had plans to expand.  Hochheiser           
          did not say whether petitioner had plans to expand.                         





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