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the Herkeios Group.2 Petitioners paid $2,950 to Freedom
Enterprises for a trust package which they used to convey the
business, and they received no consideration from the Herkeios
Group in the exchange.
The Herkeios Group continued to operate the window-washing
business under the name of J.S. Khalsa. Mr. Maranto served as
the general manager, and he performed accounting and bookkeeping
services, handled bidding work, and washed windows. Following
the transfer to the trust, the gross receipts from the business
were deposited into an account at International Savings Bank in
San Diego, California. Mr. Maranto was a signatory to this
account.
Beginning in March 1991, petitioners executed five unsecured
"Universal Notes" in favor of the Herkeios Group. These notes
were in the following amounts and bore the following interest
rates:
Interest Payment
Date Amount Promisee Rate Date
3/31/91 $4,000 Herkeios Group 5 percent 3/31/92
5/10/91 1,100 Herkeios Group 5 percent 5/10/92
5/28/91 3,400 The Herkeios Group - 0 percent 5/28/91
Alex Yung, Trustee
6/19/91 1,000 Herkeios Group dba 5 percent 12/31/91
J.S. Khalsa Co.
7/29/91 2,500 J.S. Khalsa Co. 5 percent 7/19/92
(The Herkeios Group)
2Mr. Maranto started J.S. Khalsa Co. in 1985 and operated it
as a proprietorship before the transfer to the Herkeios Group.
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