Robert C. Coborn, Sr. - Page 9

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               The evidence establishes that, after 1988, EPL continued to            
          operate as a business.  Petitioner continued to seek a sale of              
          the stock of EPL, and EPL conducted ongoing business activity.              
          In 1989, a new business plan for EPL was formulated, and in 1992            
          a public offering of EPL stock occurred.  Significantly, after              
          1988, petitioner continued to transfer funds to EPL.  The                   
          evidence does not demonstrate that EPL's purported debt to                  
          petitioner became worthless in 1988.                                        
               For the reasons stated,                                                
                                             Decision will be entered for             
                                        respondent.                                   



























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