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(2) The actual disbursement of these funds shall be
US5,000 to [petitioner’s] designated account with US
Bank, and US4,000 to Kumiko Talmage’s personal account
as designated by RBT.
(3) Further NCPL agrees to loan [petitioner] marriage
settlement monies in the event of a successful
settlement with Kumiko, the specific details of which
shall be determined by [a] separate loan agreement.
NCPL wishes Ron and Kumi the best in their settlement
of this matter and hope for a peaceful and speedy
reconciliation.
Petitioner did not report the $4,000 portion of his salary
disbursed to Kumiko Talmage as income on his Form 1040 for 2000
(2000 return).
The purported loan reconfirmation agreement with NCPL, dated
June 16, 2000, stated:
Between:
New Century Properties Limited of 2503 Bank of America
Tower, 12 Harcourt Road, Hong Kong (“Lender”),
and:
Ronald B. Talmage of 35701 NE Chamberlain Road, Corbett,
Oregon 97019 (“Borrower”)
Whereas:
Ronald B. Talmage and his spouse, Kumiko W. Talmage
collectively executed a Loan Agreement dated the 25th
of January 1999 (“The Loan”) with Lender,
and
Ronald B. Talmage and his spouse, Kumiko W. Talmage are
jointly the owners of a certain property located at
35701 NE Chamberlain Road, Corbett, Oregon, USA (“The
Property”),
and
Ronald B. Talmage and his spouse, Kumiko W. Talmage
collectively have an existing liability with regards to
funds borrowed from the Lender, via The Loan and have
pledged certain security via The Loan inclusive of The
Property itself,
and
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Last modified: March 27, 2008