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activities on Schedules C (Profit and Loss from Business) for
their 1990 and 1991 income tax returns.
a. Bass Town Tract, Sadie Farm, and Greenview Tract
Bass Town tract was a farm that petitioner bought with a
loan from First American Savings and Loan. Petitioner had
difficulty selling the Bass Town tract because of changes in land
development rules in Sampson County. Petitioner sold the Bass
Town tract for a profit after 1991.
In 1990 and 1991, petitioners owned several chicken houses
at Sadie Farm.
Petitioner could not sell the Greenview tract for
development because of wetlands problems.
b. Giddonsville Packing Tract
At a time not stated in the record, petitioner bought a 5-
percent interest in Giddonsville Packing Co., a company that
packaged and marketed vegetables grown by its owners. Petitioner
signed a promissory note making him jointly liable for the
purchase with several other owners.
The company made a profit the first 2 years but lost money
thereafter. Two of the persons who cosigned the note with
petitioner filed petitions in bankruptcy. Petitioner was the
only person who signed the note from whom the bank could collect.
Petitioner bought the interests of the other Giddonsville Packing
Co. owners so he would not be associated with a foreclosure. He
financed the purchase with unsecured short-term notes.
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Last modified: May 25, 2011