A. Lee Petersen and INI Builders, Inc. - Page 22

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          May 16, 1984.  Following a jury trial in June 1991, petitioner              
          was acquitted of all charges.                                               
          Petition in Bankruptcy                                                      
               On March 15, 1993, petitioner filed a petition under chapter           
          7 of title 11 of the U.S. Code.  The schedule of debts annexed to           
          the petition filed in that proceeding listed the IRS as a                   
          creditor in the amount of $86,504 for the taxable years 1984,               
          1986, and 1987.  On June 22, 1993, the bankruptcy court entered             
          an order releasing petitioner from all dischargeable debts.                 
          Petitioner was represented in the bankruptcy proceeding by Roger            
          McShea (McShea).  McShea never received any contact from the IRS            
          concerning the attempted discharge of petitioner's taxes.                   
          INI                                                                         
               On October 14, 1991, INI was involuntarily dissolved by the            
          Alaska commissioner of corporations.  On August 20, 1993,                   
          respondent sent notices of deficiency to INI for TYE 9/84, in               
          care of petitioner, and to petitioner for 1984 and 1986.  The               
          deficiency determined against INI is attributable to the                    
          disallowance in full of the deduction claimed in respect of the             
          $100,000 accrual of the bonus payable to Burke.  On November 16,            
          1993, petitioner filed a petition with this Court on behalf of              
          himself and INI.                                                            
               The parties have stipulated that INI's current and                     
          accumulated earnings and profits for the years in issue were                





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