Harbor Bancorp & Subsidiaries - Page 22

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               In 1988, Mr. Newman pleaded guilty to criminal charges in              
          connection with the issuance of other purported tax-exempt bonds            
          that supposedly closed on December 31, 1985.  Mr. McCown resigned           
          from DLJ and, in 1990, pleaded guilty to aiding and abetting the            
          filing of false tax returns in connection with the Matthews &               
          Wright tax-exempt bond transactions.  Mr. Goldberg was indicted,            
          with others, in connection with certain bond transactions in the            
          Territory of Guam and negotiated a plea arrangement.                        

          Petitioners' Bond Purchases                                                 

               On July 25, 1986, Harbor Bancorp acquired Whitewater bonds             
          with a face amount of $250,000.  In the same month, the Keiths              
          acquired Ironwood bonds with a $400,000 face amount and                     
          Whitewater bonds with a face amount of $300,000.  Harbor Bancorp            
          received $19,375 of interest on the Whitewater bonds in each of             
          the years 1988, 1989, and 1990.  The Keiths received $54,250 of             
          interest on the Whitewater and Ironwood bonds in each of the                
          years 1989, 1990, and 1991.  Neither Harbor Bancorp nor the                 
          Keiths included the interest received on the Bonds in the gross             
          income that they reported on their Federal income tax returns for           
          the years in issue.                                                         
               On February 20, 1991, the Commissioner notified the Housing            
          Authority that the interest paid on the Bonds would be treated as           
          taxable income to the bondholders unless the Housing Authority              
          paid, to the United States, the amount required by section                  




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