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the funds held by Aldergrove, in conjunction with petitioners'
concession that Aldergrove was the source of the funds allegedly
loaned to petitioner by Hansa Finance, $200,000 ($23,382 +
$176,618) on March 1, 1987, and $110,000 on March 1, 1988, cast
doubt on petitioners' version of the loan transactions.
A reasonable inference to be drawn from the sua sponte
issues is that petitioner's relationship with Aldergrove did not
change between February 26, 1987, and December 22, 1988, which
would mean that petitioner controlled Aldergrove partnership
matters and benefited from and controlled the funds held by
Aldergrove when Aldergrove likely transferred to Hansa Finance
the funds that were loaned back to petitioner. Therefore,
petitioners would have us believe that petitioner (1) in
substance, transferred funds to Hansa Finance, (2) borrowed those
funds back from Hansa Finance, (3) made loans with those funds to
Chestnut Grove and Group M, (4) removed himself from the loan
transactions by means of certain agreements, (5) received
interest payments from Chestnut Grove and Group M by means of his
relationship with Aldergrove on December 26, 1991, but (6) held
the interest in trust for Mr. Bell because Mr. Bell was the
ultimate source of the funds loaned to Chestnut Grove and
Group M.
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