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During 1981 and 1982, Mr. Korchak received compensation and
other taxable distributions from Halcon and/or its subsidiaries
(collectively, Halcon distributions) totaling $1,539,269 and
$466,309, respectively. Petitioner and Mr. Korchak made a
considered judgment not to change their family’s lifestyle in any
way as a result of Mr. Korchak’s having received such distribu-
tions. They made that judgment because they did not want to
spoil their children by having a lavish lifestyle. Mr. Korchak
invested a large portion of the Halcon distributions that he
received during 1981 and 1982. Although petitioner was generally
aware that Mr. Korchak invested a large portion of such distribu-
tions, she was not aware of the specific investments that he
made.
From the time in 1986 when Halcon and its subsidiaries
ceased business operations and no longer employed Mr. Korchak
until around 1995, Mr. Korchak received very little income.
Starting in 1990 until at least the time of the trial, Mr.
Korchak worked for Performance Coatings Corporation (Perfor-
mance), a new company that he and several others started in that
year. Mr. Korchak received very little, if any, compensation
from that company during the first several years of its exis-
tence. At the time of the trial, Mr. Korchak, who was 71 years
old, was president of Performance for which Performance paid him
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