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Jasbon was responsible for making arrangements with his
Government contacts in Venezuela so that ITG could enter into an
export/import contract with the VNTA. The plan was that Mr.
Jasbon would use his contacts to obtain licenses to import the
automobiles into Venezuela.
On January 15, 1993, petitioner sent Mr. Jasbon $32,408.98
by electronic transfer from Riggs Bank to Caracas, Venezuela.
Petitioner advanced the funds to Mr. Jasbon to pay business
expenses for the office that Mr. Jasbon established for ITG in
Caracas, Venezuela. Petitioner obtained the funds through cash
advances using his personal credit cards.
In March 1993, petitioner traveled to Venezuela to meet with
Mr. Jasbon to assist in the process of obtaining an import
license. Sometime during 1993, and after petitioner transferred
funds to Mr. Jasbon, the President of Venezuela resigned after
being accused of corruption. Mr. Jasbon lost his business
contacts with representatives of the Venezuelan Government
because of the political unrest. Petitioner and Mr. Jasbon were
unable to obtain an import license.
Neither petitioner nor Mr. Jasbon, as corporate officers of
ITG, ever obtained an import license from the Venezuelan
Government to transport automobiles from the United States to
Venezuela. No automobiles were ever purchased or shipped to
Venezuela. After 1993, neither petitioner, nor Mr. Jasbon, nor
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