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financial information. Joseph J. Hasman (Hasman), an attorney
representing Northwest, came to believe that petitioner’s failure
to provide the records was deliberate.
In attempting to trace funds, Northwest concluded that
petitioner had opened more than 20 different brokerage accounts
in the names of various individuals into which he placed
corporate funds during 1987 and 1988.
Petitioner’s Guaranty of Corporate Indebtedness to Northwest
By March 18, 1988, Northwest officials knew that
petitioner’s corporations’ debt to Northwest far exceeded the
$3,231,921 set forth in the January agreement. Consequently, at
Northwest’s request, on March 18, 1988, petitioner, individually
and on behalf of his corporations, executed a written personal
guaranty (Guaranty). Under the Guaranty, petitioner personally
guaranteed the prompt payment to Northwest at maturity of all the
past and future monetary obligations of petitioner’s corporations
which arose out of ticket sales.
One day before signing the Guaranty, petitioner transferred
the contents of P-B No. 1, an account in his name, to the Sam Han
account, registered in his brother’s name. This transfer
included the Kodak stock at issue in this case, as well as stocks
valued at $582,356 and debit memos of $573,610 not at issue in
this case. In addition, as noted previously, on March 8, 1988,
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