Kenneth B. and Linda R. Satlin - Page 6

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          ITG attempted to export or ever exported any automobiles from the           
          United States to Venezuela.                                                 
               In September 1993 and again in March 1994, petitioner                  
          traveled to Florida to speak with Mr. Jasbon about the                      
          possibility of entering into a business opportunity in                      
          Switzerland.  Petitioner returned to Florida sometime in June               
          1994 “to get some answers” from Mr. Jasbon regarding the funds              
          petitioner had sent him in January 1993.  Once in Florida,                  
          petitioner learned that Mr. Jasbon had moved.  In 1996,                     
          petitioner had a telephone conversation with Mr. Jasbon regarding           
          another business opportunity.  During this conversation Mr.                 
          Jasbon promised to repay petitioner.  After this telephone                  
          conversation, petitioner faxed a business proposal to Mr. Jasbon            
          for his review; however, Mr. Jasbon did not respond.  Petitioner            
          and Mr. Jasbon had no further communications after 1996.                    
               On April 1, 1994, ITG’s corporate charter was terminated for           
          failure to pay corporate dues.  After March 1994, petitioner did            
          not perform any duties as ITG’s senior corporate vice president.            
          Secured Creditor Status                                                     
               On July 7, 1983, petitioners sold two residential properties           
          to David P. Sparks and Wanda M. Sparks (hereinafter the debtors).           
          The properties were at 3513 and 3532 Buffalo Court in Woodbridge,           
          Virginia.  Petitioners received two notes secured by two deeds of           







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