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$463,944 and $213,708 during 1986 and 1987, respectively.
Petitioner continued along this path late into 1987 when Cities
was removed from the Century project. After that point, no funds
were advanced by petitioner, and his involvement with Ms. Jackson
and Cities ceased.
As of the end of 1988, it was apparent from Ms. Jackson’s
December 1988 letter to petitioner that Cities and its contracts
were dormant and that the only hope depended on the mere
possibility that Ms. Jackson could develop and finance another
project or business from which petitioner could be paid. As
mentioned in the 1988 letter to petitioner, Ms. Jackson was
attempting to obtain financing for several promotions she had
conceptualized. Considering Ms. Jackson’s financial situation
and past business performance, it would be pure speculation to
expect any possibility of petitioner’s being repaid.
During 1988 and 1989, Ms. Jackson and Cities were, for all
purposes, without resources and Cities was dormant until the time
bankruptcy was declared, first in 1990, to attempt a
reorganization, and then in 1991, when it was converted into a
liquidating proceeding. The declaration of bankruptcy was
foreordained from the time the Century project was canceled late
in 1987. Petitioner was listed as a creditor with a claim of
$659,000 in the liquidating bankruptcy. Although Ms. Jackson and
Cities did not formally declare insolvency or bankruptcy until
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