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Espinosa joined Lidak Biopharmaceuticals, later known as Lidak
Pharmaceuticals (Lidak), as its president and chief executive
officer. During the latter part of 1989, Mr. Espinosa purchased
106,000 shares of stock in Lidak. Then, on July 31, 1990, Mr.
Espinosa transferred all of his Lidak shares to petitioner’s
grantor trust. The transfer was made for no consideration other
than love and affection, at a time when Mr. Espinosa was involved
in a dispute with Lidak’s chairman of the board over a project
that the company was funding. In September of 1991, Mr. Espinosa
was terminated from his position at Lidak and has since been
unemployed.
Assets of Mr. Espinosa
All significant assets owned by Mr. Espinosa at the time of
his 1986 divorce were awarded to Colleen Espinosa. During the
period of 1989 through 1990, his assets consisted of two checking
accounts, a savings account, two certificates of deposit, and a
brokerage account. Although the record does not reveal the
status of these accounts on July 31, 1990, petitioner offered
financial statements reflecting the following balances on the
dates indicated:
Account Type Date Account Balance
Checking Account 8/12/90 $7,763.93
(La Jolla Bank)
Checking Account 3/8/90 36,448.03
(First Interstate Bank)
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