Stanley P. Zurn - Page 24

          $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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