Steven K. Han - Page 8





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               As a consequence of Northwest’s procedures for collecting              
          payment for ticket stock from its consolidators, petitioner’s               
          corporations were able to postpone payment for ticket stock for             
          significant periods.  In addition, before 1987, IL NA Tours was             
          frequently late in remitting payment to Northwest; after the                
          initiation of the more expedited procedures in 1987, IL NA Tours’           
          payment delays intensified.                                                 
               During the periods that petitioner’s corporations held                 
          ticket sales proceeds, petitioner would invest them in the stock            
          market.  Petitioner enjoyed speculating in the stock market,                
          frequently purchasing heavily margined4 stock.  Petitioner used             
          various brokerage accounts for purposes of investing his                    
          corporations’ funds, including ticket sales proceeds, in the                
          stock market.                                                               
               During 1987, petitioner opened the following three brokerage           
          accounts, among others:  (1) Account No. 682-07658 at Merrill               

               4 “Margin” is a method of buying securities on credit                  
          extended by the brokerage firm handling the purchases.  The                 
          securities are used as collateral for the loan.  The brokerage              
          firm establishes a margin account for the customer.  The initial            
          amount of funds in the margin account (initial margin) is                   
          regulated by the Federal Reserve Board.  In addition, the                   
          brokerage firm specifies the minimum amount (maintenance margin)            
          below which the balance in the margin account may not fall before           
          the brokerage firm will request that either more cash or                    
          securities be added to the margin account or the securities be              
          sold (margin call).  Modern Dictionary For the Legal Profession             
          517 (1993).                                                                 






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