Martin H. Tonn and Lorraine A. Tonn - Page 4




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          “on-farm energy plant”.3  In 1981, Mr. Tonn sold the on-farm                
          energy plant to Laurington Corp. (Laurington), his wholly owned             
          corporation.  Under the terms of the sale, payments were to be              
          made in installments.  Between 1981 and 1983, Laurington sold the           
          on-farm energy plant to three partnerships.  Payments were also             
          to be made in installments.  The three partnerships were:  (1)              
          Laurington Energy Properties; (2) Independent Energy Systems I;             
          and (3) Independent Energy Systems II (collectively, the                    
          Alternative Energy entities).  Before 1987, the Alternative                 
          Energy entities entered into a royalty agreement with IEEI,                 
          whereby IEEI agreed to manufacture and sell on-farm energy plants           
          and pay the Alternative Energy entities royalties on the sales.             
          IEEI owned or leased property in Kiel, Wisconsin, where it                  
          planned to manufacture on-farm energy equipment.                            
               Sometime before March 27, 1987, respondent filed liens                 
          against the property of IEEI.  On March 27, 1987, respondent’s              
          agents entered the property of the IEEI plant in Kiel, Wisconsin,           
          and posted a notice of seizure.  On the same day, respondent’s              
          agents went to Citizens State Bank in Kiel, Wisconsin, and agreed           
          to discharge the liens against the IEEI property in exchange for            
          the payment of $22,500.  Citizens State Bank was a creditor of              
          IEEI and also had liens against the IEEI property.  The payment             


               3The “on-farm energy plant” was an ethanol-based power                 
          system for farms.                                                           





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