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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
7(...continued)
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
(continued...)
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