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stock did not become worthless in 1995 because those alleged
activities continued after 1994. Petitioners argue that
respondent’s contention is a concession that FabuGlass was
largely an operating company in Russia in 1990-94. We disagree.
Respondent’s contention was contingent on our finding that
FabuGlass operated in Russia in 1990-94. We have not so found.
d. Whether FabuGlass Stopped Doing Fiberglass-Related
Business in 1995
Petitioner contends that FabuGlass stopped doing fiberglass-
related business in 1995 when he decided that FabuGlass would no
longer conduct any fiberglass-related business. We disagree.
There is no evidence that FabuGlass did business related to
fiberglass production or sales after November 1987.
The record shows no activity by FabuGlass in 1988 except for
petitioner’s letter to the U.S. Attorney to try to retrieve the
FabuGlass molds that the DEA had seized. FabuGlass reported no
sales or costs of goods sold in 1989. In 1989, it rented out its
Conway premises for $66,000 and invested $922,370 in securities.
The fact that FabuGlass invested nearly $1 million in 1989
suggests that it did not need those funds to pay operating costs.
The fact that FabuGlass rented out its Conway premises suggests
that FabuGlass was no longer using the Conway premises for
manufacturing or other business activities in 1990-94 because it
was no longer an operating company.
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