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
Northeast.
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
estimate.
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