Thomas F. and Toyia A. Noons - Page 6




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          located in the Cayman Islands (AMI Offshore).  From AMI Offshore,           
          the funds were transferred to AMI’s bank account at Texas Commerce          
          Bank in Houston (AMI Domestic).  AMI purchased the Forum 303 note           
          using the funds deposited with AMI Domestic.                                
          Subsequent Forum 303 Note Transactions                                      
               Forum 303, Ltd., began making monthly payments on its note to          
          AMI beginning on March 28, 1988.  Monthly payments for May, June,           
          and July totaling $105,101 were deposited into the AMI Domestic             
          account.  Thereafter, the funds were routed through AMI Offshore            
          to the Unicorn Trust account in Guernsey.  Although Forum 303,              
          Ltd., continued to make monthly payments to AMI, no funds were              
          transferred to the Unicorn Trust account after July 1988.                   
               On November 9, 1988, Mr. Rea rescinded the Forum 303 note              
          transaction and received $376,664 (the remaining unpaid amount on           
          the note) from FSLIC.  (Apparently AMI had the right to rescind the         
          transaction at any time.)  Mr. Rea did not inform petitioner that           
          the transaction was being rescinded.  Instead of repaying Unicorn           
          Trust, Mr. Rea kept the proceeds.                                           
               In 1992, petitioner, on behalf of Unicorn Trust, sued Mr. Rea          
          for failing to repay the loan owed by AMI to Unicorn Trust.  In             
          1997, petitioner had the case dismissed without prejudice after             
          deciding the debt was not collectible.  AMI never filed corporate           
          tax returns reporting income from the Forum 303 note.                       








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