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Commonwealth to The Ultimate Comeback was “grandfathered” in and
paid zero for their membership in phase I. Some members paid a
reduced amount for their phase I, II, and/or III memberships, and
brokers sold the memberships at cost ($125 for phase I, $625 for
phase II, and $3,125 for phase III). Additionally, many members
did not pay administrative fees.
The Ultimate Comeback offered another program unrelated to
the Credit Maze. The Ultimate Comeback’s orientation guide
states that in the “Wealth Preservation” program (Wealth
Preservation), participants paid $625 to purchase a manual that
discussed financial instruments used to preserve assets. The
broker5 for the Wealth Preservation member received 80 percent of
the $625 payment.
The Ultimate Comeback maintained membership lists for Wealth
Preservation and phases I, II, and III compiled by phase, member
name, and broker name. Mr. Key’s name is listed as the broker
for 21 people in Wealth Preservation, 67 people in phase I, 40
people in phase II, and 13 people in phase III.
Mr. Key requested that payments to himself and The Ultimate
Comeback be made in cash, cashier’s checks, or money orders.
Petitioners failed to maintain any tax records (i.e., general
5 In order to be a Wealth Preservation broker, a member had
to recruit two additional Wealth Preservation members.
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Last modified: May 25, 2011