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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The Stipulation of Facts is incorporated by this reference.
Petitioner resided in Long Beach, California, at the time he
filed his petition.
I. Purported Acquisition of Gas Station and Minimarket
On June 7, 1989, petitioner signed an agreement with
Glendale Federal Savings and Loan Association (the Agreement).
The Agreement modified the terms of an escrow arrangement
previously entered into by petitioner. Petitioner did not submit
documents relating to the earlier arrangement. The Agreement
pertained to petitioner's proposed acquisition from Israel and
Sonya Dakar of a gas station and minimarket (the Business)
located at 2990 Pacific Avenue in Long Beach, California. The
Agreement indicated that petitioner was to purchase the Business
but that the Dakars would retain ownership of the physical
premises on which the Business was located. The Agreement
further indicated that petitioner had deposited $10,000 in an
escrow account, planned to deposit an additional $140,000 in the
account, and would execute a $175,000 promissory note and
security agreement obligating him to make monthly payments to the
Dakars. Petitioner did not submit documentary evidence to
establish that he ultimately transferred the funds in the escrow
account to the Dakars or that he purchased the Business.
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