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nominee to receive and hold Northeast's assets. Norkevicius was
a vice president of the bank. For purposes of distributing the
remaining assets of Northeast, Northeast's creditors agreed, in
August 1980, that Norkevicius would distribute money that she
recovered as follows: the first $200,000 was to be distributed
to the bank, and the next $1.6 million was to be given 50 percent
to the bank and 50 percent to the other parties. This agreement
was based on how much Northeast owed to each party. Norkevicius
had collected $726,000 when the agreement was signed.
D. Calta, Inc.
After Northeast and Sigma collapsed, petitioner began
working for a company that Mrs. Scofield had formed called Calta,
Inc. (Calta), a Massachusetts corporation. Calta was in the
printing business. When petitioners moved to New Hampshire in
1981, she reincorporated Calta in New Hampshire. Petitioner
worked for Calta from 1981 to 1983 and received a salary of about
$5,000 a month.
E. Petitioner's Litigation Relating to Northeast
Petitioner incurred legal expenses as a defendant in
lawsuits brought by the bank, Northeast, CNI, Zayre, and
Norkevicius (as nominee), and in related bankruptcy proceedings.
1. Petitioner's State Court Proceedings
On June 12, 1982, the bank, Northeast, CNI, Zayre, and
Norkevicius (as nominee), sued McKee, petitioner, Timothy Samway,
Robert E. Davis, Francoise Sterling, Sigma, and Wingfoot in the
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