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reflects petitioner as the borrower and Seiyo as the lender, as
follows:
Loan Loan Amount Interest
Date (Yen) Rate Conditions
7/31/86 50,000,000 Short-term prime Payment of principal is
rate of payment the priority
8/30/86 52,000,000 Short-term prime Payment of principal is
rate of payment the priority
11/29/86 20,000,000 Short-term prime Payment of principal is
rate of payment the priority
12/31/86 13,000,000 Short-term prime Payment of principal is
rate of payment the priority
3/31/87 32,000,000 Short-term prime Payment of principal is
rate of payment the priority
6/30/87 30,000,000 Short-term prime Payment of principal is
rate of payment the priority
9/30/87 29,000,000 Short-term prime Payment of principal is
rate of payment the priority
12/31/87 27,000,000 Short-term prime Payment of principal is
rate of payment the priority
3/31/88 158,000,000 Short-term prime Payment of principal is
rate of payment the priority
6/30/88 28,000,000 Short-term prime Payment of principal is
rate of payment the priority
9/30/88 27,000,000 Short-term prime Payment of principal is
rate of payment the priority
12/31/88 27,000,000 Short-term prime Payment of principal is
rate of payment the priority
3/31/89 28,000,000 Short-term prime Payment of principal is
rate of payment the priority
5/31/89 400,000,000 Short-term prime Payment of principal is
rate of payment the priority
6/30/89 31,000,000 Short-term prime Payment of principal is
rate of payment the priority
9/29/89 21,000,000 Short-term prime Payment of principal is
rate of payment the priority
Tsukamoto was not aware of some of the advances listed in the
aforementioned document. No copies of individual promissory
notes evidencing the advances were received.
On September 30, 1995, petitioner's balance sheet reflected
an outstanding loan of $18,018,708.85, as well as accrued
interest of $5,856,327.97, shown as payable to Seiyo. Patrick
Kubota (Kubota), petitioner's treasurer and project manager from
1986 through 1994, was responsible for petitioner's accounting
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Last modified: May 25, 2011