Billie and Florence Lykins - Page 3

          a coal-related business.  Mr. Templeman is petitioner Florence              
          Lykins' (Mrs. Lykins) son.                                                  
               Mr. Templeman and John Adkins (Mr. Adkins) were sole, equal            
          partners in J & M Equipment Co. (J & M), a partnership engaged in           
          the business of leasing, as lessor, heavy machinery used for                
          grading and excavating property connected with construction                 
          projects and coal mining.  The record does not clearly indicate             
          the specific amount of J & M's outstanding liabilities; however,            
          it appears that J & M had outstanding liabilities of                        
          approximately $700,000.                                                     
               Mr. Templeman and Mr. Adkins were also sole, equal                     
          shareholders in Tag Coal Corp. (Tag Coal), a corporation that               
          performed grading and excavation services for construction                  
          projects located in eastern Kentucky.  Tag Coal leased equipment            
          from J & M in order to conduct its business.  Tag Coal was the              
          primary lessee and customer of J & M.                                       
               In August 1984, Tag Coal was performing general excavation             
          work for Commonwealth Development Corp. (Commonwealth).  Although           
          Tag Coal was ultimately liable for employment taxes incurred in             
          connection with the excavation work, the terms of the contract              
          between Commonwealth and Tag Coal required Commonwealth to pay              
          the employment taxes incurred by Tag Coal.  However, before the             
          project was completed, Commonwealth filed for bankruptcy and                
          failed to pay $175,970.51 in employment taxes owed by Tag Coal.             
          Commonwealth also failed to pay approximately $1,000,000 in other           

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