Self Heating and Cooling, Inc., Transferee - Page 4

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               On May 2, 1995, the Department of Taxation of the State of             
          Ohio sent Self Oil a demand for immediate payment of motor fuel             
          tax of $1,745,938.84 plus a 30-percent penalty for a total amount           
          due of $2,269,720.49.  On May 5, 1995, the State of Pennsylvania            
          assessed excise tax liabilities, including interest and                     
          penalties, against Self Oil totaling $6,599,435.56.  According to           
          three separate notices of reassessment, all dated April 5, 1996,            
          the State of Pennsylvania notified Self Oil that on the basis of            
          the decision and order that the Board of Finance and Revenue                
          entered on February 27, 1996, Self Oil owed excise tax                      
          liabilities, including penalties and interest, totaling                     
               At some point, Mr. Self, Sr., and Mr. Self, Jr., concluded             
          that Self Oil could not continue in business if it remained                 
          liable for the excise taxes asserted by Ohio and Pennsylvania.              
          Mr. Self, Sr., and Mr. Self, Jr., had discussions with their                
          attorneys, Maury B. Reiter and William Stewart, concerning a                
          method by which the business of Self Oil could be sold to                   
          petitioner.  Mr. Reiter wrote a memorandum dated January 6, 1996,           
          to his file concerning the “Pennsylvania State Motor Fuel Oil Tax           
          Appeal”, which states in whole:                                             
               On or about September 29, 1994, WKS [Mr. Stewart] and MBR              
               [Mr. Reiter] met with Robert Self Sr. (“Bob”) and Robert               
               Self Jr. (“Rob”) regarding an assessment for fuel oil tax              
               arising out of the circumstances which lead to a criminal              
               indictment and settlement.  Specifically, the State claimed            
               a [sic] that Self Oil had engaged in a “daisy chain” for the           

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