Stephen F. Scofield and Nancy E. Scofield - Page 6

          Sigma was about $500,000 early in 1980.2  At that time, Sigma had           
          four or five employees.  From late 1980 to 1981, petitioner was             
          Sigma's only employee.  Sigma was sometimes a customer of                   
               Sigma paid petitioner a salary of $143,333 in 1979.                    
               Sigma ceased doing business in September 1981.                         
               4.   Norcel, Inc.                                                      
               In May 1980, petitioner incorporated a company called                  
          Norcel, Inc. (Norcel).  He was Norcel's only officer, director,             
          and shareholder.                                                            
               5.   Wingfoot Corp., Ltd. and Alar, Ltd.                               
               Petitioner was a stockholder and officer of Wingfoot Corp.,            
          Ltd. (Wingfoot), a Canadian corporation.  He did not earn a                 
          significant amount of income from Wingfoot in 1978 and 1979.                
               Petitioner started a company in Hamilton, Bermuda, named               
          Alar, Ltd., at a time not stated in the record.                             
          C.   Northeast's Collapse                                                   
               1.   Cessation of Northeast's Business Activity                        
               Petitioner resigned as an officer from Northeast on June 20,           
          1980.  In mid-1980, Northeast ceased doing business.                        
               2.   Creditors' Agreement                                              
               On August 11, 1980, the bank, CNI, Zayre, and Meredith-                
          Burda, Inc. appointed Virginia Norkevicius (Norkevicius) as                 

               2 The record does not indicate how petitioner used this                

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