Edward B. Rood - Page 5

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          petitioner from $250,000 to $435,000.  That balance was                     
          attributable to credit extended by Caesar’s prior to December               
          1985.  When informed of the returns of the checks, petitioner               
          promised to make arrangements to clear them and, subsequently, to           
          send new checks.  In the course of a contact with Caesar’s                  
          concerning the returned check for $110,000, petitioner also                 
          inquired when the $250,000 balance of his account was due, and              
          Caesar’s informed him that it was due January 12, 1986.  On                 
          December 23, 1985, Caesar’s received a check for $110,000, which            
          was returned due to insufficient funds on January 15, 1986.                 
               During 1986, petitioner made the following payments on his             
          account:                                                                    
                         Date                 Amount                                  
                    May 13, 1986             $25,000                                  
                    Aug. 11, 1986            10,000                                   
                    Dec. 3, 1986        10,000                                        
          The IOU envelope for petitioner’s account sets forth the                    
          following notation with respect to a contact with petitioner on             
          January 8, 1987:  “Got him [petitioner] straight[en]ed out about            
          25M pmt [payment] which we rec back in 5/13/86--verified balance            
          & pmts [payments] made & he agrees”.  Caesar’s sent petitioner an           
          account statement dated February 4, 1987, informing him that its            
          executive committee had approved a lump-sum settlement in a                 
          reduced amount and inviting him to call its account                         
          representative for details.  During 1987 and 1988, petitioner               
          made payments on his account as follows:                                    




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