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execute in favor of seller a first trust deed and note
as his interest appears in the total amount of $48,000,
payable $608.04 or more per month including 9% interest
until paid.
By letter dated October 31, 1986, Stello Real Estate
informed petitioner and Charlotte that a buyer for the property
had been found and that the buyer's offer should be accepted.
Petitioner and Charlotte authorized Stello Real Estate to sell
their interest in the property by a note dated November 3, 1986.
In that note, petitioner instructed Stello Real Estate to change
its records to show that he and Charlotte would henceforth do
business as C and C Liberty Enterprises (C and C). Petitioner
informed Stello Real Estate that C and C's Federal I.D. number
was 52-1370927. The property was sold, and this is one of the
transactions from which Services collected interest income which
it distributed to petitioner.
Ms. Stello testified that when Services first establishes an
account for a client, Services sends a thank you note to the
client and encloses an amortization schedule and a request for
the client's Social Security number. Ms. Stello did not receive
a Social Security number from petitioner.
In 1990, Ms. Stello sent a letter to petitioner informing
him that she had sent him four requests for his Social Security
number and had received no response to each of her letters. In
response to her 1990 letter, Ms. Stello received a telephone call
from petitioner during which he informed Ms. Stello that he would
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