Daniel J. Culnen - Page 3




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                                  FINDINGS OF FACT                                    
               Some facts have been stipulated and are so found.  The                 
          stipulation of facts, with attached exhibits, is incorporated               
          herein by this reference.                                                   
               At the time the petitions were filed, petitioner resided in            
          Totowa, New Jersey.                                                         
          Wedgewood Associates, Inc.                                                  
               During the years in issue, Wedgewood Associates, Inc., a New           
          Jersey corporation (Wedgewood), was an S corporation, see sec.              
          1361(a)(1), making its return of income on the basis of a                   
          calendar year.  Wedgewood was in the restaurant business.  In or            
          before 1987, petitioner became a shareholder in Wedgewood.                  
          Beginning in 1987 and ending in 1990, petitioner owned the                  
          following percentages of Wedgewood’s shares:                                
                         Year                Percentage                               
                         1987                39.48                                    
                         1988                52.00                                    
                         1989                73.00                                    
                         1990                73.00                                    
          Wedgewood was unsuccessful in the restaurant business.  It ceased           
          doing business sometime in 1990, and, on or about March 14, 1990,           
          by Deed of Assignment for the Benefit of Creditors (the deed), it           
          conveyed its property for the benefit of those creditors.                   
          Attached to the deed is a “Statement of Assets”, which lists                
          restaurant fixtures, equipment and furnishings subject to liens             
          of $1,865,000, a liquor license, cash on hand, accounts                     





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