Jean A. Stanko - Page 6

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          to June 1985, petitioner was more involved in Stanko Packing's              
          daily operations than she had been previously.  She controlled              
          Stanko Packing’s checkbook and paid Stanko Packing's expenses.              
          She also reviewed its bank statements and sometimes talked to               
          Stanko about whether to pay Stanko Packing's expenses.  She had             
          detailed knowledge about the operations of R.G. Stanko Express.             
          During this time, she communicated with accountants at Fred                 
          Lockwood & Co. about Stanko Packing.  Fred Lockwood was Stanko              
          Packing's accountant until the summer of 1985.  Petitioner knew             
          that Stanko Packing's records had been seized, presumably by law            
          enforcement officials, in late 1984 or 1985.                                
               In March 1985, petitioner had Stanko Packing pay her $1,500            
          for her work on its behalf.                                                 
          C.   Transfers of Stanko Packing Assets to Stanko and Petitioner            
               in 1984                                                                
               1.   Stanko Packing's Transfer of Assets to Stanko in 1984             
               On September 17, 1984, Stanko Packing transferred the                  
          Packerland note, cash, and other property to Stanko, which made             
          Stanko Packing insolvent.  Petitioner knew that Stanko Packing              
          transferred the note to Stanko.                                             
               2.   Stanko's Transfers to Petitioner in 1984                          
               Stanko transferred the following property to petitioner on             
          September 17, 1984:  (a) 250 shares of Sugar Valley stock; (b)              
          4,000 shares of Butch's Cattle Co. stock; (c) 500 shares of                 
          Jackson Feeders stock; and (d) 500 shares of stock in the School            





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