Don Ballantyne and Susanne C. Ballantyne - Page 8

          BTG Corp.                                                                   
               BTG Corp. (BTG) was incorporated in Delaware on September 28,          
          1981.  Prior to July 30, 1985, BTG was a dormant corporation.               
               BTG had been formed by AMCOR, a California corporation, which          
          incorporated and sold other corporations primarily to attorneys for         
          tax planning activities.  From 1984 to 1988, AMCOR had only two             
          employees, Robert Burton (Burton) and Lisa Aspoy.  Ms. Aspoy is,            
          and at all relevant times was, the wife of Mark Schiavenza                  
               Schiavenza is an attorney specializing in the field of                 
          taxation.  From October of 1975 to January or February of 1981, he          
          practiced law with Harry Margolis, whose tax planning strategy              
          (which involved the circular transfer of funds through the use of           
          offshore entities, trusts, and shell corporations) has been                 
          repudiated by this Court on numerous occasions.  See Marine v.              
          Commissioner, 92 T.C. 958 (1989), affd. without published opinion           
          921 F.2d 280 (9th Cir.1991); Erhard v. Commissioner, T.C. Memo.             
          1991-290, modified T.C. Memo. 1992-376 and T.C. Memo. 1993-25,              
          affd. 46 F.3d 1470 (9th Cir. 1995); Leonard v. Commissioner, T.C.           
          Memo. 1985-51, affd. without published opinion sub nom. Robinson v.         
          Commissioner, 816 F.2d 684 (9th Cir. 1987).                                 
               Schiavenza represented various real estate developers and              
          referred them to AMCOR as clients.  Schiavenza also represented             
          Escondido Property Investment Corp. (EPIC), Oi Weng Co. Ltd., a             

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