Self Heating and Cooling, Inc., Transferee - Page 2

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          whether petitioner is liable as a transferee of property pursuant           
          to section 6901.1                                                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          When the petition was filed, petitioner’s principal place of                
          business was in Fort Washington, Pennsylvania.                              
               On July 1, 1971, Self Oil Heat, Inc. (Self Oil), was                   
          organized pursuant to the laws of Pennsylvania to engage in,                
          inter alia, the business of selling fuel oil.  Self Oil elected             
          to be treated for tax purposes as an S corporation until that               
          election was revoked on or about April 12, 1996.  From the date             
          of its incorporation until the date it ceased operations, Robert            
          N. Self, Sr., was Self Oil’s president, sole shareholder, and               
          sole director.  For part of 1991 and 1992, Robert N. Self, Jr.,             
          was Self Oil’s secretary and treasurer.2                                    
               During 1993, Self Oil and its officers became the subject of           
          a joint criminal investigation conducted by Federal and State               
          authorities to determine whether Self Oil, among others, had paid           

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the year at issue, and              
          all Rule references are to the the Tax Court Rules of Practice              
          and Procedure.                                                              
               2Mr. Self, Sr., is the father of Mr. Self, Jr., and Jonathan           
          Self.  Mr. Self, Sr., testified that both of his sons were former           
          employees of Self Oil.                                                      

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