Edward W. and Edith M. Arnold - Page 6




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         country (such as a bank account, securities account, or other                
         financial account).  In 2001 and 2002, however, petitioners sent             
         money to Orion via wire transfers to banks and beneficiaries in              
         St. Kitts, West Indies, and Nevis, West Indies.                              
              Orion purportedly invested in foreign currency trades that              
         could net returns of 6 percent to 8 percent per month and 60                 
         percent to 200 percent per year.  Orion appears to have been, in             
         part,2 a Ponzi scheme.  Many investors, however, successfully                
         withdrew funds from Orion, which built customer confidence that              
         Orion’s operations were legitimate and that the returns and gains            
         Orion reported to customers, including petitioners, were real.               
              In December 2003, petitioners received a letter from the                
         U.S. Postal Inspection Service (USPIS), dated December 15, 2003,             
         that indicated that petitioners might have been victims of fraud             
         associated with Orion.  Following receipt of the December 15,                
         2003, letter from the USPIS, petitioners attempted to recover                
         funds they had transferred to Orion.  During 2004, a newspaper               
         printed a story about Orion which stated that the founder of                 
         Orion was suspected of misusing money provided to Orion.                     
         Sometime after reading the 2004 newspaper article, petitioners               
         believed that any money they provided to Orion was lost and that             
         their interest in Orion was worthless.                                       


               2  Some of the money Orion received was invested in currency           
          trades.                                                                     






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