- 45 - (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.Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 NextLast modified: March 27, 2008