Ronald B. and Annette C. Talmage - Page 45




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               (8) Ronald shall herewith proceed to make arrangements with            
               Counsel and to notify appropriate parties to begin this                
               process, and notify NCPL accordingly. * * *                            
          C.   Events After Issuance of Notices of Deficiency                         
               The notices of deficiency for 1998, 1999, 2000, 2001, and              
          2002 were issued on April 11, 2005.                                         
               On June 17, 2005, NCPL incorporated RiverCliff Farm, Inc.              
          (RFI), as a solely owned subsidiary under the laws of the State             
          of Oregon for the purpose of operating a vacation home for NCPL.            
          Ms. Chen was named the president and petitioner was named the               
          secretary of RFI.  The articles of incorporation for RFI list               
          Robert G. Burt, P.C., as the registered agent, and Robert G.                
          Burt, Attorney at Law, as the incorporator.                                 
               Although the appraised fair market value of the Rivercliff             
          property was only $5,670,000 as of June 30, 2005, petitioner                
          transferred title, by quitclaim deed, to RFI for $12,608,786 on             
          June 30, 2005.15  The $12,608,786 comprised $6,869 in cash, a               
          $3,528,068 promissory note, forgiveness of the $519,033 NCPL                
          advanced to petitioner to purchase the Rivercliff property, and             
          other advanced funds totaling $8,554,816.16                                 



               15 According to an appraisal prepared by Matthew P. Call of            
          PGP Valuation, Inc., for petitioner’s attorney, Robert G. Burt,             
          the Rivercliff property had a fair market value of $5,670,000 as            
          of June 30, 2005.                                                           
               16 NCPL purportedly assigned the $519,033 and $8,554,816 to            
          RFI as receivables.                                                         






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