Ernst L. Meier - Page 14




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               Blackland’s monthly balance sheets from January 1, 1996,               
          through the end of November of 1996, reflect that Blackland’s               
          stated loan balance owed to petitioner was reduced by $33,293               
          from $2,979,568 to $2,946,275.  On Blackland’s December 31, 1996,           
          balance sheet, the stated loan balance owed to petitioner was               
          indicated as zero.                                                          
               The evidence in the record does not reflect that petitioner            
          ever made a formal demand for repayment from Blackland of the               
          funds he transferred to Blackland between 1993 and 1995, and                
          petitioner never attempted to obtain a monetary judgment against            
          Blackland based on the funds transferred.                                   
               The only accounting books and records of petitioner (as                
          distinguished from Blackland) relating to the funds he                      
          transferred to Blackland during 1993 through 1995 that are in               
          evidence in this case consist of the above-mentioned worksheets.            
          No income statements, balance sheets, general ledgers, journals,            
          or complete bank account statements of petitioner relating to the           
          funds he transferred to Blackland are in the record.                        
               With regard to Blackland’s financial records, the                      
          evidentiary record in this case includes Blackland’s unaudited              
          monthly and annual income statements and monthly balance sheets             
          for 1992 through 1996, and general ledger accounts for limited              
          periods of time.                                                            
               Blackland was dissolved on March 28, 1997.                             






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