Paul G. Gubbini - Page 6

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          corporation.  Stanley Prentice and his wife also returned their             
          100 shares of stock in Color Trick to the corporation during                
          February 1989.                                                              
               Toward the end of 1989, petitioner concluded that Color                
          Trick could not generate sufficient income to pay its bills, that           
          its business could not be turned around, and that he could not              
          continue advancing money to the business.  Petitioner’s efforts             
          to sell Color Trick around that time were unsuccessful.  Except             
          for activities connected with winding down its business, Color              
          Trick ceased operations at the end of 1989.  Its equipment was              
          sold or foreclosed upon and available funds were used to repay              
          certain creditors, not including petitioner.                                
               Leland Prentice had no assets from which petitioner’s loans            
          could have been repaid.  Petitioner did not attempt to foreclose            
          on or to sell the patent.  The process had become obsolete by the           
          end of 1989 because of the widening availability of digital                 
          printers.  Petitioner received no repayment of principal or                 
          payment of interest with respect to the loans and advances he had           
          made to Color Trick.                                                        
               On his Federal income tax returns for 1987, 1988, and 1989,            
          petitioner claimed the following losses with respect to Color               
          Trick:                                                                      
                    Year                 Loss                                         
                    1987                $9,053                                        
                    1988                42,982                                        
                    1989                78,356                                        




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