Allen C. Chamberlin and Martha L. Chamberlin - Page 7

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          mortgages on the Greenwich residence.  Petitioner also personally           
          guaranteed a loan of $300,000 from Ingersoll-Rand that was made             
          to his incorporated medical practice.                                       
               In 1983, petitioner purchased Bel-Mar Laboratories (Bel-               
          Mar), a company whose principal purpose was the manufacture of              
          parenteral products.  Parenteral describes liquid medication                
          injected by syringe or needle directly into the bloodstream of a            
          patient.  Petitioner became the sole shareholder and chairman of            
          the board of directors of Bel-Mar, and he immediately changed the           
          name to Chamberlin Parenteral, Inc. (Chamberlin Parenteral).                
               In 1984, The Chamberlin Corp. was unable to pay its debts,             
          and, on December 17, 1984, creditors filed an involuntary                   
          chapter 11 bankruptcy petition against the company.  Petitioner             
          continued to search for outside investments to save the company,            
          and the company continued to operate at least through March 1985.           
          The assets of The Chamberlin Corp., including the Largo facility            
          that had been surrendered to the corporation by petitioner, were            
          sold to pay debts of the company in June 1985.                              
               On July 11, 1985, petitioners filed a personal chapter 11              
          petition in bankruptcy.  Petitioners did not make a section                 
          1398(d)(2) election to terminate their taxable year on                      
          commencement of the bankruptcy.  On the date of filing, debts of            
          petitioners totaled $6,319,354, while their assets totaled                  

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