- 6 - 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 Rea rescinded the Forum 303 note transaction and received $376,664 (the remaining unpaid amount on the note) from FSLIC.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 Rea did not inform petitioner that the transaction was being rescinded.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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011