Don E. Kramer - Page 5




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          other investors; however, he was unsuccessful.  Petitioner’s                
          initial investment in BERM was approximately $50,000.                       
               Shortly after the restaurant’s opening in August 1994,                 
          petitioner and Mr. Maker had disagreements over Mr. Maker’s                 
          management practices.  At that time, petitioner was winding down            
          his law practice in Marion, Illinois, about 45 miles away, and              
          was not involved with BERM full time.  Mr. Maker made numerous              
          requests to petitioner for additional money, and, after further             
          inquiry, petitioner found that Mr. Maker “was spending money like           
          there was no tomorrow.”  Petitioner also noticed a high rate of             
          employee turnover.  Because of disagreements in management,                 
          petitioner asked Mr. Maker to take a few weeks off while                    
          petitioner decided whether or not to continue with the venture.             
               In December 1994, petitioner and Mr. Maker agreed that Mr.             
          Maker would no longer have any involvement with BERM.  To this              
          end, on December 12, 1994, Mr. Maker sold his stock in BERM to              
          petitioner for $5,000, leaving petitioner as the sole shareholder           
          of BERM.  Although an agreement memorializing this sale was fully           
          executed by the parties, there are no corporate minutes or                  
          resolutions by BERM with respect to distributions to any                    
          shareholders.  In fact, BERM did not maintain a corporate minute            
          book.  After petitioner’s initial $50,000 investment in BERM, he            
          continued to use his own money or money lent to him by friends to           








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