Leonard Pipeline Contractors, Ltd. - Page 4

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               Between 1978 and 1987, petitioner had gross revenues of                
          $123,124,905 and after-tax net income of $1,705,958.  Petitioner's          
          primary source of income in 1985 and 1986 arose from its work on            
          the All American Pipeline project,2 which involved coating,                 
          insulating, and wrapping 325 miles of pipeline in Texas, Arizona,           
          and California. In connection with this project, Mr. Leonard                
          personally guaranteed petitioner's $1.5 million debt to the Royal           
          Bank of Canada.  The All American Pipeline project was finished in          
          1987; thereafter petitioner continued to receive payments on the            
          contract but undertook no new business.                                     
               In February 1987, Mr. Leonard began contemplating retirement.          
          On September 28, 1987, 2 days before the end of petitioner's tax            
          year, petitioner's board of directors (consisting of Mr. Leonard            
          and his son) voted to pay Mr. Leonard a $1.68 million bonus in              
          addition to his $97,800 salary for the year.  The board's decision          
          was purportedly based on several considerations, including: (1) Mr.         
          Leonard's efforts in obtaining the All American Pipeline project;           
          (2) Mr. Leonard's development of a new insulation process; and (3)          






               2    On Sept. 19, 1991, Mr. Leonard ultimately pled guilty             
          to a criminal information filed against him in the District Court           
          for the Southern District of Texas for obtaining the All American           
          Pipeline contract through fraud.  He was sentenced to 3 years of            
          unsupervised probation and fined $1,000.                                    





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