Norwest Corporation and Subsidiaries - Page 50

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         the PCC stock was valued at $8,000,000 when it should have been              
         valued at $681,099, Petitioner is entitled to an additional loss             
         deduction of $7,318,901 for 1987."                                           
              H.  Notice of Deficiency                                                
              In the notice of deficiency, respondent disallowed                      
         petitioner's claimed $4,577,136 loss.  The notice explains that              
         petitioner did not establish that any deductible loss was sustained          
         in 1987.                                                                     
              I.  Subsequent Events                                                   
              Petitioner attempted to sell its interest in PCC several weeks          
         after the conversion. Then, in 1992 or 1993, petitioner engaged              
         Eden International to assist in the sale of its PCC stock.  On               
         December 1, 1994, petitioner entered into a Deferred Stock Sale              
         Agreement with Tiquie, S.A., a subsidiary of IKPC located in                 
         Uruguay,  agreeing  to  sell  the  MOIL  shares  to  Tiquie  for             
         $10,500,000, consisting of $1,150,000 in cash and a $9,350,000               
         note, plus interest on the outstanding balance of the purchase               
         price.  By selling its entire interest in MOIL, petitioner                   
         indirectly sold the 14.361-percent equity interest in PCC, as well           
         as cash equivalents of approximately $658,000. Petitioner incurred           
         $260,000 in closing costs.                                                   
              Petitioner sold its remaining blocked deposits for 47 cents on          
         the dollar in January 1988.                                                  








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