Robert C. Coborn, Sr. - Page 3

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               Between 1972 and 1988, petitioner transferred at least                 
          $1,571,429 to EPL.                                                          
               Over the years, EPL obtained a number of loans from banks.             
          These loans were personally guaranteed by petitioner.  Funds that           
          petitioner individually transferred to EPL were not secured and             
          were subordinated to bank loans EPL obtained.                               
               Not until September of 1990 did petitioner take steps to               
          secure funds he alleges to have loaned to EPL.                              
               Between 1973 and 1984, a series of purported promissory                
          notes were executed on behalf of EPL and in favor of petitioner             
          that apparently related to some of the funds petitioner                     
          transferred to EPL.  Neither petitioner nor EPL, however,                   
          maintained adequate, current documentation and accounting records           
          reflecting funds petitioner transferred to EPL.  Certain                    
          documentation relating to the funds petitioner transferred to EPL           
          appears to have been originated not at the time the funds were              
          transferred but in later years.                                             
               Of the $1,571,429 that petitioner alleges constituted funds            
          he loaned to EPL, $729,248 thereof is not reflected by any                  
          purported promissory notes.                                                 
               At some point in time, an undated document was executed on             
          behalf of EPL and in favor of petitioner indicating that                    
          petitioner agreed to loan over an unspecified period of time an             







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