Charles B. Owens and Sally L. Owens - Page 5




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          correspondence) includes a copy of a “Dormant Account Status                
          Approval Form” with respect to the loan, which shows an effective           
          date of October 6, 1994.  The form contains the following                   
          statement:  “This memorandum is a request for Authorization to              
          write off the remaining balance of $1,338,924.32”.2  Under the              
          heading “1099 Will be Generated”, the preparer marked the space             
          adjacent to the entry “Not Economic to Pursue and Unsalable”.               
          The form also contains a brief narrative describing the loan and            
          the status of collection efforts with respect thereto.  The                 
          narrative references a July 1994 asset search that revealed no              
          assets available for repayment of the loan.  The narrative                  
          concludes:  “It does not appear to be cost effective to pursue a            
          collection lawsuit against the obligor.”  The form bears the                
          stamp “REQUEST APPROVED BY OVERSIGHT COMMITTEE SPECIAL ASSET                
          BANK” with a handwritten date of October 20, 1994.                          
               The FDIC correspondence also includes two pieces of                    
          correspondence between petitioner and Wayne D. Eckstine, a                  
          principal of AMRESCO.3  In a letter to Mr. Eckstine dated                   
          November 1, 1994 (the November 1 letter), petitioner reiterates             
          his reluctance to provide current financial information in light            
          of the adverse effect such information may have on certain other            



               2  The form lists principal of $596,078 and interest of                
          $742,846.32.                                                                
               3  AMRESCO apparently managed certain loan accounts on                 
          behalf of the FDIC.                                                         




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