A. Lee Petersen and INI Builders, Inc. - Page 20

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          The Audit Reopened                                                          
               By letter dated November 21, 1989, the IRS reopened its                
          audit of INI.  Petitioner responded by submitting to the IRS a              
          signed statement that purported to explain the events that led to           
          his settlement with the Burke estate.  This statement had several           
          documents attached, including a letter from petitioner to Thorpe            
          dated November 30, 1984.   The letter sets out a purchase price             
          of $37,500 for Burke's stock, and provides that bonuses in the              
          amounts of $12,500 and $100,000 would be paid to Burke, for a               
          total to the estate of $150,000.  It gives petitioner credit for            
          having already paid $6,382 against the $37,500 purchase price for           
          the stock and calls for a $30,757 note, with interest at the rate           
          of 14 percent and payments over a 2-year period.  The letter                
          states that petitioner and Burke had agreed to pay excess INI               
          profits out in bonuses instead of allowing the profits to                   
          accumulate with the corporation.  Page 2 of the letter also calls           
          for Thorpe's signature to indicate agreement.  Thorpe did not see           
          the November 30, 1984, letter until sometime in 1986.  Thorpe               
          refused to sign the November 30, 1984, letter because the letter            
          was dated 1984 and misrepresented the arrangement between                   
          petitioner and the estate.  Petitioner told the IRS that the                
          November 30, 1984, letter constituted the actual reformation of             
          the buy-sell agreement.  Petitioner admitted at trial that the              
          November 30, 1984, letter is not the actual agreement.                      





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