Kevin R. Johnston - Page 11




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          also testified that neither petitioner nor Ms. Ghavami was a                
          beneficiary of Isiah 18 or Oak Harbor.                                      
               Mr. Chisum claims that he was either Universal’s “trustee”,            
          or an officer or agent of Universal’s “trustee”, from Universal’s           
          formation in 1990 until the time of trial, except for the period            
          from October 1991 until May 1993.                                           
          Additional Facts Relating to Petitioner’s Services                          
               Petitioner is a licensed real estate salesperson in the                
          State of California.  At some time not specified in the record,             
          Walter Blazyk (Mr. Blazyk), the president of World Wide Mortgage            
          Corporation (WWMC), approached petitioner and asked him to work             
          for WWMC.  Petitioner agreed to do the work provided that WWMC              
          pay Universal for the work done.                                            
               During 1993, petitioner worked for WWMC and a few other                
          parties.  Also during that year, WWMC paid Universal $95,596 for            
          work done by petitioner; the other parties paid Universal $7,824            
          for work done by petitioner.  As set forth above, this $103,420             
          paid for petitioner’s services was deposited into Universal’s               
          bank account.                                                               
               Petitioner alone did the work for which WWMC paid Universal            
          the $95,596 during 1993.  As far as WWMC was aware, Universal was           
          not involved in making any of the business decisions necessary to           
          produce this income.  Moreover, Universal was never involved in             
          the working relationship between petitioner and WWMC.  Mr.                  





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