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name ROLICH was derived from the names of the three children:
Robert, Lisa, and Christine. When petitioner needed money for
any reason, his father wired the funds to him. ROLICH was a
family corporation, and each of the five family members (i.e.,
petitioner's father, mother, and the three children) was an
officer of ROLICH.
In 1987, petitioner's father participated in a leveraged buy
out of UNAKA Corp. (UNAKA) and obtained petitioner's signature
pledging petitioner's assets in this buy out. Petitioner was
unaware at that time that he owned substantial assets.
Petitioner and his sisters were named directors and officers of
UNAKA and were given annual salaries of $20,000 each. After his
father's death, in 1990, petitioner learned for the first time
that he was an owner of UNAKA and that he was liable for a debt
of $40 million for the buy out. UNAKA owned a number of
subsidiary companies, including Metals Engineering Company
(MECO), a company which manufactured metal folding furniture, and
Southern Packaging Company (SO-PAK), a company which produced
packaged military food rations. Any dividends from MECO or SO-
PAK would have been paid to UNAKA as sole shareholder.
Petitioner does not know if he was an officer of MECO or of SO-
PAK during 1988. During 1988, petitioner was paid $20,000 in
compensation from UNAKA as a director or officer; petitioner did
not receive this compensation directly and did not learn of it
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