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Toberman, and that as of the end of 1992, the corporation owed
petitioner $457,072.
Bankruptcy Proceeding
In 1990, petitioner filed for relief under chapter 11 of the
United States Bankruptcy Code. On May 21, 1991, petitioner’s
bankruptcy case was dismissed for petitioner’s failure to file a
disclosure statement and plan of reorganization as directed by
the United States Bankruptcy Court.
Judgments Against Petitioner
Before 1993, a number of judgments were entered against
petitioner in favor of various creditors.
IRS Collection Information Statement
In 1993, petitioner submitted to the Internal Revenue
Service (IRS) Form 433-A, Collection Information Statement for
Individuals (CIS), signed and verified by petitioner on March 3,
1993, as true, correct, and complete. On the CIS, petitioner
reported that he had a net worth of approximately $389,650.7 On
the CIS, petitioner reported no outstanding loans from either
Bonnevista or Castle Towers. On the CIS, petitioner disclosed
neither his ownership interests in Fantastic Foods nor any
receivables from Fantastic Foods (Delaware). Petitioner reported
7 The Collection Information Statement for Individuals (CIS)
indicates that as of Mar. 3, 1993, petitioner had assets
comprising $50 cash and real estate worth $850,000 (subject to
encumbrances of $460,000), and had $400 of credit card debts.
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