Raymond B. and Joan M. Marvin - Page 4




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          provide reliable evidence that would support these assertions.              
          The sole document that petitioners provided is entitled                     
          "Custodial Trust Contract".  The document purports to be a                  
          contract between Glacial Jadeite and a company called Creative              
          Technology Alliance (CTA).  The contract provides that Glacial              
          Jadeite will hold in trust for CTA $600 million worth of jade and           
          that CTA will use the jade as collateral to acquire loans for               
          Glacial Jadeite.  Petitioners failed to provide documents that              
          describe CTA.  Moreover, petitioners have not provided any                  
          evidence that demonstrates that Glacial Jadeite possesses $600              
          million worth of jade or that CTA has the ability to secure                 
          financing for Glacial Jadeite.  Petitioners further claim that in           
          accordance with the contract, deposits of $25 million and $65               
          million were placed in an escrow account in Orlando, Florida.               
          Petitioners failed to present documents that substantiate these             
          alleged deposits.                                                           
               Petitioners did not maintain formal accounts or books for              
          the jade activity.  Instead, petitioners contend that they used             
          their personal checking accounts and credit cards to pay the jade           
          activity's expenses.  Petitioners also failed to provide a                  

          1(...continued)                                                             
          of the hotels will be constructed of black jade and grouted with            
          gold and platinum.  Petitioners also allege that Glacial Jadeite            
          is involved in the construction of a stadium that will be                   
          constructed entirely out of jade.  Petitioners also claim that              
          Bill Gates of Microsoft has offered to purchase Glacial Jadeite             
          for $273 million.                                                           





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