Melvyn L. Bell - Page 18

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          purpose for BEI.  Kaufman Lumber was profitable when BEI acquired           
          a 50-percent interest in December 1986.  Neither BEI nor                    
          petitioner made an effort to resell Kaufman Lumber at a profit.             
          Instead, BEI acquired the remaining 50 percent of the company in            
          1989 and continued to hold it at the time of petitioners' divorce           
          in 1991.                                                                    
               Petitioner argues that he has a history of rehabilitating              
          and selling businesses for a period of nearly 30 years.  There is           
          some evidence in the record that petitioner had a reputation in             
          his community as a business entrepreneur.  Petitioner had                   
          interests in about 20 businesses in addition to the BEI                     
          subsidiaries.  Petitioner contends that he also held these                  
          entities as part of his business of promoting and developing                
          businesses.  However, there is no credible evidence that the                
          other business enterprises were held as inventory for resale.  We           
          cannot determine from the record the length of time that                    
          petitioner held the businesses, and it appears that petitioner              
          held them for considerable periods of time without any intention            
          of selling them.  Only a few of these businesses were marginally            
          profitable, and petitioner did not take any affirmative steps to            
          advertise or sell them.  Evidence offered by petitioner at trial            
          shows that he successfully turned around and sold only three                
          companies (Southern Blueprint, Nygem, Consumat) over a period of            
          30 years.  Petitioner's accountant was not aware of a single                
          instance where petitioner successfully rehabilitated a struggling           
          company apart from ENSCO.  Petitioner's prior business activity             


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