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located in the first story of the building located at 1349 N.
Wells Street.
As a result of a dispute among the partners, the assets of
the Festival Partnership were placed into receivership in 1976.
The assets of the Festival Corp. were eventually added to the
receivership. On March 24, 1978, the receiver turned over the
Bijou and the building in which it was operated to petitioner.
Petitioner's Poor Financial Condition During Receivership
During the receivership years (1976-1978), petitioner had
serious financial problems. Petitioner borrowed from numerous
relatives, was frequently overdrawn on his personal checking
account, made minimum payments on his credit card balances, and
took a job performing menial tasks at his in-law's business.
Petitioner's Business Interests as of May 1978
From May 1978 through December 1982, Entertainment &
Amusement, Inc., a corporation incorporated in the State of
Illinois (E&A of IL), operated the Bijou. Petitioner was the
president of E&A of IL at all times and was the sole shareholder
of E&A of IL until 1981. In 1982, petitioner was at least a 50-
percent shareholder of E&A of IL.
On October 1, 1981, Entertainment and Amusement, Inc., was
incorporated in the State of California (E&A of CA). Petitioner
was the sole shareholder and president of E&A of CA. E&A of CA
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