Mehdi H. Hajiyani - Page 12




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                    The Fuller Loans                                                  
               In October of 1990 Edwin Fuller executed a promissory note             
          payable to petitioner for $30,000 secured by a first deed of                
          trust on unimproved property located in the State of Maryland.              
          In 1991, Mr. Fuller agreed to sell the property to Michael Mason            
          subject to the deed of trust.  In September of 1991, Mr. Mason              
          executed a promissory note for $68,000 payable to petitioner                
          secured by a first deed of trust.  The $68,000 face amount of the           
          note was to retire the Fuller note for $30,000 with the remaining           
          $38,000 intended to fund a construction loan the proceeds of                
          which were to be released in stages.  At settlement Mr. Mason               
          received a construction draw of $6,000.                                     
               On March 2, 1993, petitioner foreclosed on the property.               
          Because Mr. Mason had failed to pay the required property taxes,            
          petitioner paid property taxes of $7,147 before receiving title             
          to the property.  Petitioner, having received title to the                  
          property, sold it in 1999.                                                  
                    The International Loan Network Loans                              
               In November of 1991 petitioner purchased at a discount from            
          Merwin Coad two promissory notes each secured by a second deed of           
          trust on respective properties located in Washington, D.C.  Each            
          note was in the amount of $10,500 for which he paid $8,500.  In             
          1991 the maker of the notes, International Loan Network, filed              
          for bankruptcy.  The trustee in bankruptcy subsequently                     






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