Mark N. Wright and Erica Y. Wright - Page 11

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          application fee of $2,000 to create an offshore investment                  
          package, which consisted of a legal opinion letter regarding the            
          U.S. tax law compliance of CLGs,12 and an investment portfolio              
          that included CLGs and petitioners’ Leadenhall bank account and             
          Mastercard credit card.  Mr. Wright, acting through Hal Jones               
          (Mr. Jones), a Cash-4-Titles promoter, created the CLGs to be               
          conduits to funnel his and his clients’ funds to a new mutual               
               The mutual fund was set up and run in the Bahamas by                   
          Cardinal International, which, in turn, was supposed to have                
          invested the funds in the U.S. title loan business a.k.a Cash-4-            
          Titles.  Ms. Mohr invested in a CLG called Blues Brothers Limited           
          (Blues Brothers), and petitioners invested in CLGs called                   
          Britannia, Footpaths Limited, and Sarasota Investment Club #2.              
          The Mastercard credit card that Leadenhall issued to, and that              
          was used by, petitioners was in the name of one of their CLGs,              
          Sarasota Investment Club #2.                                                
               Shortly after petitioners and Ms. Mohr made the investments,           
          Cash-4-Titles was shut down by the SEC.  A class action lawsuit             
          and a lawsuit by the court-appointed receiver were commenced                
          against Bank of Bermuda by or on behalf of the American                     

          No. 18, sec. 7 (1992).                                                      
               12The opinion letter was issued by Dean & Heimos, L.L.C., a            
          Colorado law firm.                                                          

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