Robert Fedewa - Page 4




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          Background                                                                  
               In 1976, petitioner and his brother, James Fedewa, and                 
          cousin, Bernard Fedewa, formed a partnership known as BBJ                   
          Investments (BBJ).  BBJ is a Michigan partnership in the business           
          of acquiring and operating residential real estate.  Initially,             
          the partnership was owned equally by the three partners.  On July           
          6, 1987, James Fedewa relinquished his one-third interest in BBJ            
          to petitioner.  Since 1987, petitioner has held a two-thirds                
          interest in BBJ.  Petitioner was also either a shareholder or               
          partner in Fedewa Enterprises, Fedewa Builders, Fedewa Realty               
          World, and Construction Redi-Mix (collectively the related                  
          entities).  The related entities were involved in the development           
          and construction of residential and commercial properties through           
          the 1980s.                                                                  
               In 1975, BBJ purchased land to build a 50-unit apartment               
          complex known as North Scott Villa.  In order to complete the               
          North Scott Villa project, Bernard E. Fedewa, James R. and Mary             
          Ann Fedewa, and Robert E. and Julia I. Fedewa, as the “borrower”            
          secured a $712,500 loan bearing 8.5-percent interest (FmHA loan),           
          from the Department of Agriculture Farmers Home Administration              
          (FmHA) in 1975.  Pursuant to the loan agreement, the borrower was           
          required to provide annual budgets, annual operating plans, and             
          maintain books and records relating to the housing project’s                
          financial affairs, causing such books and records to be audited             






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