-50-
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.
Page: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 NextLast modified: May 25, 2011