Archie L. and Louise B. Honbarrier - Page 18




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               Colonial terminated its business of hauling packaged freight           
          in 1988.11  It then began selling its operating assets.  From               
          1988 forward, Colonial had no customers.  By the end of 1990,               
          Colonial had essentially disposed of its trucking operation                 
          assets for cash and cash equivalents.  The only trucking assets             
          Colonial retained were its ICC and North Carolina operating                 
          authorities.  The ICC operating authority had become worthless,             
          and Colonial sold its North Carolina operating authority in 1992            
          for $5,000.  For 3 years prior to the merger, Colonial’s assets             
          consisted principally of tax-exempt bonds and a municipal bond              
          fund.12  During the 3-year period prior to the merger, Colonial             
          held 18 tax-exempt bonds, 16 of which were purchased in 1990 and            
          1991, and 2 of which were purchased in 1992.  One bond was                  
          redeemed in 1991, and three bonds were redeemed in 1992 and 1993.           
          Colonial continued to hold the remaining 14 bonds as of the end             
          of 1993.                                                                    
               Colonial stopped hauling freight approximately 5 years prior           
          to the merger, had essentially sold all of its operating assets 3           
          years prior to the merger, and for 3 years prior to the merger              
          kept most of its assets in tax-exempt bonds and a municipal bond            

               11Colonial principally transported furniture manufactured in           
          North Carolina.                                                             
               12The passive income from these money management activities            
          caused Colonial to lose its S corporation status at the end of              
          its 1992 tax year pursuant to sec. 1362(d)(3).  For the taxable             
          year 1993, Colonial was a C corporation and Central was an S                
          corporation.                                                                




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