Manaharlal C. Parekh and Elizabeth Parekh - Page 6

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          informed the Texas Rangers of their suspicion that Wheeler had              
          stolen money from PEC.  By the end of 1987, petitioner believed             
          he knew how much Wheeler had stolen from either him or PEC.                 
          Wheeler died in 1989.                                                       
               Petitioners did not claim a theft loss deduction on their              
          1985, 1986, 1987, or 1989 income tax return.  On or about October           
          15, 1992, petitioners timely filed an amended tax return and a              
          claim for refund for the 1988 taxable year.  Petitioners based              
          their claim for refund upon a theft loss deduction in the amount            
          of $374,922.45 which they allege Wheeler stole from petitioner.             
          On July 21, 1995, the Internal Revenue Service denied                       
          petitioners' claim for refund for the 1988 taxable year.                    
          Default on Bank Loan by PEC                                                 
               In 1988, PEC was unable to make payments due under the note.           
          In August 1988, the bank turned to petitioner to perform on his             
          guarantor agreement.  On January 11, 1989, the bank obtained a              
          default judgment against petitioner (the default judgment) in the           
          amount of $1,105,552.75 with respect to petitioner's guaranty on            
          the note.  On April 13, 1989, the bank obtained from the Texas              
          State District Court a temporary restraining order to enjoin                
          petitioner from conveying, encumbering, or disposing of any of              
          his assets.                                                                 
               On April 21, 1989, petitioner filed for protection under               
          chapter 11 of the Bankruptcy Code in the U.S. Bankruptcy Court              





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