John S. and Christobel D. Rendall - Page 36

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               Solv-Ex’s plan of reorganization was approved by both the              
          U.S. and Canadian bankruptcy courts in 1998, whereupon Solv-Ex              
          emerged from the joint bankruptcies and, thereafter, continued to           
          operate.  Moreover, under the plan, Mr. Rendall received                    
          5,728,767 shares of new Solv-Ex common stock in discharge of the            
          $2 million loan (plus interest).  Because the number of shares              
          Mr. Rendall received was based upon the actual bid price for                
          Solv-Ex common stock on the date immediately prior to the date of           
          receipt (50 cents a share), those shares obviously had a value              
          greater than zero upon receipt by Mr. Rendall.                              
               Lastly, Mr. Rendall testified at trial that the lawsuits               
          commenced in 1998 against Deutsche Bank and others, after Solv-             
          Ex’s discharge from bankruptcy, entailed the potential recovery             
          of $100 million for Solv-Ex.                                                
               Although the arrangements for commercializing the Ti02S                
          technology in Venezuela, Solv-Ex’s emergence from bankruptcy, the           
          conversion to common stock of the $2 million loan, and the suits            
          against Deutsche Bank and others all occurred in 1998, we may               
          “take cognizance of subsequent events in confirming whether a               
          debt becomes worthless in a particular year.”  Crown v.                     
          Commissioner, 77 T.C. 582, 600 (1981).                                      
               Petitioners have not persuaded us that the joint                       
          bankruptcies were identifiable events demonstrating the                     
          worthlessness of the $2 million loan as of December 31, 1997.               






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