Manaharlal C. Parekh and Elizabeth Parekh - Page 7

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          for the Western District of Texas, El Paso Division (the                    
          bankruptcy court).  On April 27, 1989, the bank filed an Original           
          Verified Complaint and Application for Temporary Restraining                
          Order and Preliminary Injunction combined with Complaint for                
          Declaratory Judgment (the complaint) in petitioner's bankruptcy             
          case.  The complaint sought to offset a pension fund deposit                
          account and two commercial checking accounts maintained by                  
          petitioner at the bank against the amount owed by PEC to the                
          bank.  On or about August 7, 1989, the bank filed an Amended                
          Proof of Claim in petitioner's bankruptcy case in the amount of             
          $1,108,472.60.  In response to the complaint, the bankruptcy                
          court entered an order (the order) in January 1990 which                    
          permitted the bank to exercise setoff rights on $260,000 of funds           
          from petitioner's bank accounts and required petitioner to pay              
          approximately $190,000 to the bank from petitioner's property               
          acquired after filing the bankruptcy petition, for a total of               
          $450,000.                                                                   
               On February 7, 1990, petitioner and his bankruptcy estate,             
          through bank offsets and direct payments, paid a total of                   
          $450,000 to the bank in satisfaction of the bank's Amended Proof            
          of Claim.  On petitioners' 1990 joint income tax return,                    
          petitioners claimed deductions for NOL's from the bankruptcy                
          estate and for expenses to protect petitioner's business                    
          reputation in the amounts of $299,920 and $143,070, respectively.           





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