Archie L. and Louise B. Honbarrier - Page 4




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          North Carolina.  Colonial hauled freight in conventional van                
          trailers pulled by highway tractors.                                        
               Colonial held an operating authority granted by the                    
          Interstate Commerce Commission (ICC) and an operating authority             
          granted by the State of North Carolina.  These authorities                  
          granted Colonial contract and common carrier status between                 
          specified points and places within the United States and North              
          Carolina for the transportation of packaged freight.                        
               When the trucking industry was deregulated at the Federal              
          level in the 1980's, Colonial was subjected to competition from             
          small individual truckers, with low overhead costs.  As a result,           
          Colonial’s ICC operating authority became worthless, and the                
          company experienced significant business reversals.                         
               Colonial operated at a loss in the late 1980's.  On its                
          Federal income tax returns2 for 1987 and 1988, Colonial reported            
          ordinary losses from trade or business activities as follows:               
                         Year                Loss                                     
                         1987           $1,291,408                                    
                         1988             2,245,186                                   
                         Total          3,536,594                                     
               In 1988, as a result of its financial losses, Colonial                 
          stopped hauling freight and began selling its operating assets.             
          By December 31, 1990, Colonial had sold all of its operating                



               2Colonial elected S corporation status in 1985.  At the end            
          of 1992, Colonial’s S corporation status was terminated pursuant            
          to sec. 1362(d)(3).  Colonial was a C corporation in 1993.                  





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