Mary Catherine Pierce - Page 9

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          Sethco then remitted the $300,000 to DDC as partial payment                 
          on Sethco’s loan from DDC.  Sethco continued to use this property           
          as its place of business.                                                   
               Between 1992 and 2001 several loan transactions occurred               
          among petitioner, MCU, DDC, and Sethco.  From 1992 through 1998,            
          MCU’s yearend financial statements reflected “Loans from                    
          Stockholder” with balances ranging from $414,200 to $705,200.               
          From 1993 through 1998, MCU’s yearend financial statements                  
          reflected “Notes Receivable--DDC” with balances ranging from                
          $33,150 to $536,947.  From 1995 through 1998, MCU’s yearend                 
          financial statements reflected “Notes Receivable--Sethco” with              
          balances ranging from $47,000 to $235,336.                                  
               DDC’s 1993 through 1998 annual financial statements                    
          reflected notes payable to the limited partner in the total                 
          amount of $310,000.  DDC’s 1997 and 1998 annual financial                   
          statements reflected notes receivable from Sethco in the total              
          amounts of $319,617 and $321,843, respectively.  Sethco’s 2001              
          bankruptcy petition reflected an unsecured nonpriority debt to              
          DDC in the amount of $1,385,641.  In addition, the bankruptcy               
          petition reflects that Sethco made a $300,000 payment to DDC on             
          May 4, 2001.                                                                
               On December 22, 1993, Mary Catherine, Mr. Pierce, and                  
          petitioner filed a complaint in the Connecticut Superior Court              
          against their accountants Alec R. Bobrow, David S. Bobrow, Alan             






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