Robert J. Geiger - Page 3




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          or all of that time, he served as Geiger's treasurer.  His day-              
          to-day responsibilities included managing Geiger's warehouse and             
          routing functions.                                                           
               Geiger's stock was owned by petitioner, his brother Michael             
          Geiger (Geiger's secretary), his mother Alma Geiger (Geiger's                
          president), and his sister Janice Lee Costner (Geiger's vice                 
          president).  The spouses of the Geiger siblings also held some               
          interest in Geiger's as well.                                                
               In 1988, all of the assets of Geiger's were purchased by                
          Linda K. Woodward, Incorporated.  Petitioner's employment with               
          Geiger's was terminated as a result.                                         
               After the sale of its assets, Geiger's adopted a 5-year plan            
          of liquidation.  The final distributions in liquidation were made            
          to its shareholders during 1992.  After reviewing certain of                 
          Geiger's books and records, petitioner's brother computed the                
          appropriate amounts of distributions in liquidation, and on                  
          December 12, 1992, prepared the Form 1096 and Forms 1099                     
          regarding the distributions.  Petitioner's mother was responsible            
          for making the distributions.  In calculating the amount of                  
          distributions due to his siblings, petitioner's brother included             
          the share holdings of their spouses.  Consequently, only four                
          Forms 1099 were generated; one for each Geiger sibling, and one              
          for petitioner's mother.                                                     
               In 1992, as reflected in Geiger's books and records, the                
          corporation made a $15,282 distribution in liquidation to                    
          petitioner, as one of its shareholders.                                      

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