Steven K. Han - Page 71





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          respect to the $271,836 transferred in an effort to consummate              
          his lawyer’s proposal are significant.                                      
               In transferring the $271,836 to ANB No. 2, petitioner was              
          attempting to secure release from any personal liability to                 
          Northwest for the more than $8 million he had acknowledged his              
          corporations owed the airline company.  Under the Guaranty,                 
          petitioner (without benefit of counsel) had guaranteed all past             
          and future monetary obligations of his corporations that arose              
          out of ticket sales.  In the Interim Agreement, entered into with           
          the benefit of counsel, petitioner (i) confined his personal                
          guaranty to debts arising from the receipt and sale of tickets              
          received from Northwest in 1988 (but not before); and (ii)                  
          acknowledged on behalf of his corporations that with respect to             
          pre-1988 ticket sales, his corporations had retained sales                  
          proceeds due and owing to Northwest in an amount exceeding $8               
          million.  Had petitioner been successful in securing his release            
          from all personal liability under the foregoing agreements, the             
          result would have been to saddle his corporations with the sole             
          liability for debts exceeding $8 million.  The consideration                
          petitioner proposed to use to secure his release consisted of               
          $271,836 from a personal account into which corporate funds had             
          been diverted.  Obviously, this attempt would have “primarily               
          benefitted” petitioner, see Loftin & Woodard, Inc. v. United                






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