James P. Shea and Patricia H. Shea - Page 4




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          1992.  At the time their petition was filed, petitioners                    
          Christopher M. Shea and Kim A. Shea resided in Rochester,                   
          Michigan.                                                                   
               Petitioners James P. Shea (James) and Christopher M. Shea              
          (Christopher) are brothers who, during 1992, worked at a company            
          called PK Contracting.  PK Contracting (the company) was in the             
          business of painting lines on roads.  James, a vice president of            
          the company, has worked for the company for more than 20 years              
          and is a part owner of the company.  As of the trial date,                  
          Christopher was the president of the company and ran the                    
          company’s day-to-day operations.  In 1992, Christopher was the              
          general manager, with similar operational responsibility.4                  
               None of the petitioners were in the trade or business of               
          lending money.                                                              
          The Russian Airplane Deal                                                   
               Sometime prior to January 19, 1992, James was introduced to            
          Michael Donnelly by a friend.  Donnelly, who claimed to be a                
          retired U.S. Army major general, described a plan in which he and           
          some others would buy Russian airplanes (Ilyushin-72s) for                  
          substantially less than their purported fair market value and               
          resell them in the West for $5 to $8 million per airplane or use            



               4 Petitioners Patricia H. Shea and Kim A. Shea are involved            
          in these consolidated cases only because they filed joint Federal           
          income tax returns with their husbands for 1992.                            





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