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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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Last modified: March 27, 2008