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Class A Class B
GML 10 percent 100 percent
$1,000 $569,000
Petitioner 90 percent none
$9,000
Class B partnership units were nonvoting, and, in partnership
matters affecting both classes, partners voted in proportion to
their percentage ownership of Class A partnership units.
2. GML
GML was a wholly owned subsidiary of Span Corp., Ltd.,
which, in turn, was wholly owned by Lynwood S. Bell (Mr. Bell), a
Canadian citizen residing in Anguilla. Petitioner and GML
entered into an agreement, effective July 1, 1984, that required
petitioner to manage GML's investments and to provide investment
advice. GML transferred assets to Aldergrove for management.
3. Jaguar Holdings/Ihatsu Fudosan and Hansa Finance
Jaguar Holdings, Ltd. (Jaguar Holdings), was wholly owned
and controlled by Mr. Bell, and, on or about August 1, 1988, its
name was changed to Ihatsu Fudosan Capital, Ltd. (Ihatsu
Fudosan).
Hansa Finance and Trust, B.V. (Hansa Finance), was owned and
operated by Mr. Bell.
4. Chestnut Grove and Group M
During 1991, petitioner was a 45-percent shareholder of both
Chestnut Grove Investments, Inc. (Chestnut Grove), and Group M
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Last modified: May 25, 2011