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B. Proof of Debt Claims
On January 15, 1992, the IOMB of BCCI, S.A. was placed into
liquidation by the High Court in Douglas, Isle of Man. By letter
dated March 1992, the BCCI liquidator advised potential creditors,
including petitioner, of the procedures for filing proof of debt
claims. Proofs of debt had to be filed before June 30, 1992.
Petitioner filed two claims in the IOMB of BCCI, S.A.
liquidation, one for each of her BCCI accounts. By letters dated
December 10, 1996, the liquidator advised petitioner that a 24.5-
percent "first dividend" was declared, from which petitioner would
be paid $753.46 for account No. 02013325 and $67,703.42 for account
No. 03000571.
Separate liquidations were also conducted for BCCI, S.A.'s
operations in California and New York. All creditors in the
California and New York liquidations were fully paid (100 percent).
Petitioner did not file a claim in the California liquidation.
C. "Victims Fund"
Sometime in 1995 petitioner's tax return preparer, Patricia
Vannucci, read a newspaper article indicating that a U.S. District
Court judge had ordered $393 million seized from BCCI to be turned
over to a worldwide "victims fund" to compensate depositors and
other third parties harmed by BCCI. On September 7, 1995, Ms.
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