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unaware that Cash-4-Titles was a Ponzi scheme, but was aware of
the offshore credit cards and the tax evasion opportunity they
offered, at the time he recommended it to Ms. Mohr and invested
himself.
Petitioners and Ms. Mohr made several investments in Cash-4-
Titles. The investments in which petitioners and Ms. Mohr both
participated resulted in class action lawsuits. Another
investment, in which only Ms. Mohr participated, resulted in a
National Association of Securities Dealers (NASD) claim by Ms.
Mohr against Mr. Wright for “violations of the Florida Securities
and Investor Protection Act; violations of federal securities
laws; breach of contract; common law fraud; breach of fiduciary
duty; negligence and gross negligence.”
1. Class Action Lawsuit
In the first type of investment in Cash-4-Titles,
petitioners and Ms. Mohr invested in offshore entities known as
“companies limited by guarantee” (CLGs).11 Mr. Wright paid an
10(...continued)
affect the Court’s conclusions. Thus, notwithstanding the trial
ruling admitting Mr. Sullivan’s testimony, the Court has not
considered his testimony in that regard in deciding this case.
11A company limited by guarantee (CLG) is an entity of
United Kingdom origin that does not have an exact counterpart in
U.S. tax law. Bahamian law defines a “company limited by
guarantee” as “a company [that] is formed on the principle of
having the liability of its members limited to such amount as the
members respectively undertake to contribute to the assets of the
company in the event of a winding up”. Companies Act 1992, Act
(continued...)
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