Allie Ray McCullen and Shurley G. McCullen - Page 4

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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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