9
Stanko Packing overpaid its income tax for the taxable year
ending August 25, 1984, by $29,741, which it applied as a credit
toward its income tax liability for the following year.
3. Dissolution of Stanko Packing
Stanko Packing sold its remaining assets in the fall of
1984. Those assets were not valuable.
On February 8, 1985, Stanko Packing filed Form 1120, U.S.
Corporation Income Tax Return, for the 52-53 week-annual period
ending August 25, 1984. Stanko Packing did not file an income
tax return for its last taxable year, which ended on June 21,
1985. On June 21, 1985, Stanko Packing filed Articles of
Dissolution with the State of Nebraska, dissolving Stanko Packing
on that date. Stanko Packing's income taxes for its tax year
ending June 21, 1985, have not been paid.
4. Payments on the Packerland Note
Petitioner rejected an offer (not otherwise identified in
the record) to buy the Packerland note for $2.2 million in the
first year she held it. She rejected an offer in 1986 from
Packerland to discount the note by $500,000 because she thought
it was worth more than that.
Packerland paid all principal and interest on the note,
totaling $4,101,779.86, by July 31, 1989.
5. Stanko Farm and Ranch
In early 1985, petitioner began to operate her own farm
business, Stanko Farm and Ranch. She opened a checking account
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