Don Ballantyne and Susanne C. Ballantyne - Page 12

          subsidiary of Rea Brothers (Guernsey) Ltd.  Petitioner was the              
          "First Trust Protector" for the Marwick Trust; Susanne Ballantyne           
          was the successor trust protector.                                          
               EPIC was formed at the request of Schiavenza.  Schiavenza's            
          wife (Lisa Aspoy) was the president of EPIC during 1986, 1987, and          
               EPIC signed a management agreement with AMCOR, effective March         
          27, 1986.                                                                   
               On April 15, 1986, petitioner sold his 1,000 shares of BTG             
          stock to EPIC for $3.6 million on an installment basis.  On April           
          16, 1986, BTG liquidated and distributed all of its assets (a $1.1          
          million note from petitioner and BTG's interest in the Wine Ridge           
          Joint Venture) to EPIC.                                                     
               The $3.6 million purchase price was evidenced by a 20-year             
          installment note ($3.6 million note).  The terms of the $3.6                
          million note called for the payment of interest at the rate of 9.33         
          percent per annum, payable semiannually, beginning October 15,              
          1986.  Principal was to be paid in 20 equal installments of                 
          $180,000 per year, beginning April 15, 1987.  The $3.6 million note         
          was secured by an offshore Channel Islands escrow account managed           
          by Rea Brothers.  Funding for the offshore escrow account was to            
          come from distributions from the Wine Ridge Joint Venture (which            
          were to be made to EPIC by virtue of EPIC's interest in the joint           
          venture) and from payments due EPIC from petitioner (with regard to         
          petitioner's $1.1 million obligation to BTG).                               

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