Wilburn C. Hall, Jr. - Page 9

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             Table 1                                                                                            

                                     Date of Event                                                              
                               Pre-                                                                             
             Post-  Corporation         1982     1982     1983        1984      1985      1986                  
             1986                                                                                               
             Concordia        I 04/22/74   –-       –-       S 02/13      –-        –-       –-                 
             Six Drilling     I 12/06/77   –-       –-       S 02/13      –-        –-       –-                 
             Stroud Land      I 02/13/78   –-       –-       S 02/13      –-        –-       –-                 
             Stroud Builders  I 02/13/78   –-       –-       1S 02/14      –-        –-       –-                
             Preferred        I 06/08/78   –-       –-       S 02/13      –-        –-       –-                 
             Brazos           I 12/14/78   –-       –-       S 02/13      –-        –-       –-                 
             Empire           I 04/28/80   –-       –-          –-      S 02/19     –-       –-                 
             Paramount                                                                                          
             Farms          I 12/01/81   –-       –-       2S 02/13   R 05/30      –-  S                        
             02/10/87                                                                                           
             R                                                                                                  
             09/21/88                                                                                           
             S                                                                                                  
             02/23/90                                                                                           
             Service Rig–         –-     I 01/27    –-          –-      S 02/13     –-       --                 
             Paramount Oil        –-     I 10/15    –-          –-        –-     S 02/10     --                 
             Petron               –-       –-       –-        I 11/08     –-     S 02/10 S                      
             02/20/87                                                                                           
             R 03/11 R                                                                                          
             12/11/89                                                                                           
             1    The parties stipulated that Stroud Builders' status was suspended by the Oklahoma             
             Secretary of State's office on Feb. 13, 1984, but the stipulated report from that                  
             official states that the suspension was on Feb. 14, 1984.                                          
             2    The parties stipulated that Paramount Farms' status was suspended by the Oklahoma             
             secretary of State's office on Feb. 12, 1984, but the stipulated report from that                  
             official states that the suspension was on Feb. 13, 1984.                                          

             During the years in issue, petitioner's law practice mainly                                        

             involved clients and matters related to his business activities,                                   

             petitioner's father's business activities, and the activities of                                   

             associates he dealt with.                                                                          

             Statute of Limitations                                                                             

             Petitioner filed each of his tax returns for 1982 through                                          

             1986 late, as shown in table 2.                                                                    

             Table 2                                                                                            

             Year                  Date Filed                                                                   

             1982                 Sept. 18,1987                                                                 
             1983                 Oct.  19,1987                                                                 
             1984                 Nov.   3,1987                                                                 




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