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of the debt Self Oil owed to Harleysville National Bank totaling
$254,000.8
On April 15, 1996, the fair market value of the assets
transferred to petitioner was $680,000. Self Oil was insolvent
when it conveyed its assets to petitioner or was rendered
insolvent by virtue of the transfer. After transferring its
assets to petitioner, Self Oil ceased its business operations.
Petitioner continued the fuel oil business from the business
premises that Self Oil had previously occupied. Mr. Self, Sr.,
owned and leased the business premises.
For each of the months of May through December of 1996,
petitioner paid Mr. Self, Sr., $5,000, for a total of $35,000.
During 1997, petitioner paid Mr. Self, Sr., the following amounts
on the dates listed:
Date Amount
1/14/97 $5,000
2/10/97 5,000
4/--/971 5,000
5/12/97 5,000
5/27/97 2,000
6/9/97 5,000
7/14/97 5,000
8/11/97 5,000
9/26/97 5,000
10/13/97 5,000
11/11/97 5,000
8When Self Oil conveyed its assets to petitioner, the unpaid
balance owed to Harleysville National Bank was $410,000 on a term
note and $195,000 on a revolving line of credit. Mr. Self, Sr.,
guaranteed these debts. On June 12, 1996, petitioner paid the
outstanding balance on the revolving line of credit obligation.
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