David L. Wiksell and Margaret Ann Carpender - Page 4




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               Sometime before the spring of 1984, David began working as a           
          real estate investment adviser for Comstock Financial Services,             
          Inc. (Comstock Financial), an insurance agency owned and operated           
          by Roy L. Comstock (Comstock).  During the spring of 1984, David            
          told petitioner that Comstock was investing in Hitech.                      
               During 1984 and 1985, David maintained a business checking             
          account under the name Hitech.  Petitioner was not a signatory on           
          this account.  David periodically gave petitioner checks drawn on           
          the Hitech account and made payable to "Margaret Wiksell", which            
          she deposited into her two personal checking accounts.  In 1984,            
          petitioner was given 23 checks from Hitech totaling $54,500.  In            
          1985, petitioner received 15 Hitech checks totaling $140,500 from           
          Hitech.                                                                     
               In 1984 and 1985, petitioner wrote checks on her accounts              
          totaling $78,781.38 and $149,444.32, respectively.  Among other             
          things, these checks were used for clothes; loans to a child;               
          charitable and political contributions; entertainment and gifts;            
          home furnishings; home repair and maintenance; credit card                  
          payments; mortgage payments; and numerous other miscellaneous               
          expenses.                                                                   
               In January or February 1987, David was arrested and charged            
          with fraud in connection with a scam perpetrated by Roy Comstock,           
          Abraham Boldt, and David, wherein it was alleged that at least $2           
          million, fraudulently obtained from unsuspecting investors in               
          Comstock Financial, was diverted to Hitech.  On January 13, 1988,           



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