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became the vice president of RAI, receiving annually a salary of
$100,000 and a car allowance of $2,000. He was responsible for
conducting all of RAI's operations, which included sales,
marketing, advertising, credit, collection, and dealer relations.
Jose Garcia (Mr. Garcia) was a client of RAI. He sold,
financed, and installed alarm and security systems to consumers in
South Florida, doing business as AVD Security Systems (AVD) and
Lauren Investments (LI). Mr. Garcia regularly sold his installment
contracts to RAI.
While visiting Mr. Garcia's businesses on RAI's behalf in
April 1991, petitioner was offered the position of president of a
bank Mr. Garcia and others were creating in South Florida.
Petitioner accepted Mr. Garcia's offer.
Mr. Garcia agreed to advance money to petitioner in order to
facilitate petitioners' move from their home in Pennsylvania to
Florida. These advances were to be interest free until January 1,
1994, at which time interest would be applied to any unpaid balance
at the rate of 6 percent per annum.
In November 1991, petitioners moved to Florida. Between
October and December 1991, petitioner assisted Mr. Garcia in
preparing for the opening of the bank, which was scheduled to occur
on January 6, 1992.
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