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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
1988.
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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