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As a result of being liable for much of the debt of P.G.D.,
Mr. Streck filed a debtor's petition in the U.S. Bankruptcy Court
under chapter 7 of title 11 of the United States Code on October
14, 1983. On March 30, 1984, the Bankruptcy Court discharged Mr.
Streck from all dischargeable debts.
During 1984, petitioners, acting through Double D Ranch,
Inc., constructed a log cabin at an approximate cost of $494,000.
Petitioners used the log cabin as their residence. During 1984
and 1985, petitioners also purchased two new 1985 Mercedes Benz
automobiles, a $92,000 boat, and four Honda motorcycles. Also,
in 1985, petitioners purchased two condominiums in Florida, one
on Marco Island for $265,000 and upon its sale, another in Naples
for approximately $675,000.
During the years in issue, Mrs. Streck was the sole
shareholder of American Carriers, Inc. (ACI), and Mr. Streck was
ACI's president. Mrs. Streck was a signatory on ACI's bank
account, and she signed checks as an officer on behalf of ACI.
She also participated in voting on resolutions adopted by ACI's
board of directors. Mrs. Streck was also an officer of P.G.D.
On August 1, 1993, in connection with an ongoing audit by
respondent, petitioners submitted an Offer in Compromise (Form
656) to respondent's Appeals Officer Frank Sower with respect to
8(...continued)
employer in Knoxville. On July 5, 1996, based on violations of
the terms and conditions of his probation in connection with the
1988 convictions, Mr. Streck was reincarcerated.
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