Carrie H. Suchar, Transferee, et al. - Page 8

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               Unfortunately, John was unable to obtain financing, and in             
          April of 1998, John tragically died.  John was buried on the                
          separate parcel of real estate on which Susan lives adjacent to             
          the farm acreage and the residence acreage.                                 
               At this point, in order to keep ownership of the farm                  
          acreage and the residence acreage in the Suchar family and also             
          to provide funds to Marilou, Susan (Richard’s first wife and the            
          mother of Carrie, Tracy, and Deborah) offered to provide funds              
          for the purchase from Richard and Marilou of the farm acreage for           
          a total of approximately $45,000.  Susan effectively took over              
          John’s earlier offer to purchase the farm acreage and thereby to            
          provide the funds that were needed to pay off the mortgage and              
          taxes and to pay Marilou a portion of the value of her interest             
          in the farm acreage and the residence acreage.                              
               In April of 1998, respondent’s revenue officer contacted               
          Richard to inquire regarding unpaid delinquencies in Richard’s              
          Federal income tax liabilities for 1993 and 1994 and regarding              
          Richard’s unfiled 1995 and 1996 Federal income tax returns.3                
               Respondent’s revenue officer inspected the farm acreage and            
          the residence acreage and met with Richard in the home located on           
          the residence acreage.  Respondent’s revenue officer described              

               3  In the course of an earlier audit of Richard regarding              
          Richard’s failure to file Federal income tax returns for 1993 and           
          1994, respondent had prepared Federal income tax returns for                
          Richard for those years.                                                    






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