Mark N. Wright and Erica Y. Wright - Page 9

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          petitioners and advised Ms. Mohr to make similar investments.               
          Petitioners and Ms. Mohr invested in Cash-4-Titles, an investment           
          scheme promoted and operated by individuals and business entities           
          in the United States, the Bahamas, and the Cayman Islands.8                 
          Cash-4-Titles was in fact a massive illegitimate “Ponzi scheme”             
          later shut down by the Securities Exchange Commission (SEC),9 and           
          investigated as part of the Internal Revenue Service’s (IRS)                
          Offshore Credit Card project.10  Mr. Wright was apparently                  

          similar to a debit card.  The funds petitioners deposited in                
          their Leadenhall bank account were used to pay for the charges              
          they incurred on their Mastercard credit card.                              
               8The operation of Cash-4-Titles is explained in Ex parte               
          Dill, Dill, Carr, Stonbraker & Hutchings, P.C., 866 So. 2d 519,             
          522 (Ala. 2003), as follows: “‘ Messrs Homas and Gause raised               
          money from investors * * * that was to be loaned to C4T, which in           
          turn would finance the Cash 4 Titles’ stores to make car loans to           
          the general public.’  * * * ‘Messrs Homa and Gause agreed to pay            
          investors between 1% and 4% per month on funds loaned to C4T and            
          remit the interest payments to investors on a monthly basis.’”              
          In fact, “‘most, if not all of the investor funds were not used             
          by C4T * * * for the car title loan business.  Instead, C4T * * *           
          transferred the funds to accounts at the Bank of Bermuda in the             
          Cayman Islands controlled by Messrs Homa and Gause and used the             
          funds, in classic Ponzi scheme fashion, to pay interest to                  
          investors and pay personal expenses for Messrs Homa and Gause to            
          support their lavish lifestyle.’”  Id. at 524.                              
               9See SEC v. Homa, 2004 WL 1474580 (N.D. Ill. 2004); SEC v.             
          Homa, 2004 WL 1093492 (N.D. Ill. 2004).                                     
               10On brief and at trial, petitioners object pursuant to Fed.           
          R. Evid. 408 to the Court’s consideration of testimony by                   
          Internal Revenue Agent Robert Sullivan (Mr. Sullivan) about an              
          alleged “deal” Mr. Wright attempted to make with Mr. Sullivan               
          during the examination process.  The Court need not consider the            
          objection further because Mr. Sullivan’s testimony would not                

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