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$1,231,786. She supervised more than 30 employees. In addition
to her managerial duties, she originated loans, made accounting
for income produced by the loans, and prepared budget projections
for the branch office. The income she received from Fort Worth
Mortgage was determined at least in part by the profitability of
her branch office. To increase the profitability of her branch
office and thereby increase her income, Mowrey would arbitrage
loans originated in her branch office to take advantage of
interest rate fluctuations in the secondary mortgage market.
Robert Boehm (Boehm) was also employed in the mortgage
banking business as a loan officer. During the year in issue, he
was employed by NationsBank of Texas and reported wage income of
$43,518. In addition, Boehm assisted Mowrey in her employment.
Each month, he helped her audit loan files to determine how much
income was being produced and to compare it against the projected
budget for the branch office. Occasionally, Boehm picked up
packages for Mowrey and took photographs for the use of
appraisers. He also “kept up with” daily mortgage interest rates
and would advise Mowrey on whether or not to sell loans in the
secondary mortgage market.
During the year in issue, Boehm was president and sole
officer, shareholder, director, and employee of Crestmark.
Crestmark came into existence on December 1, 1989, as the result
of a name change of a predecessor corporation, identified in the
record only as JAWIN. Boehm testified that JAWIN “was previously
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