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2001) to convert the original dwelling on the Rivercliff property
into a storage facility so that petitioner could continue using
it as a dwelling until the new home was completed.
In 2000, NCPL wire transferred to SSI a total of $2,742,794
for the development of the Rivercliff property and a total of
$38,800 to Kumiko Talmage for petitioner’s spousal and child
support obligations. Petitioner did not report any of the
transferred funds as income on his Form 1040 for 2000 (2000
return).
On December 19, 2000, Mr. Seki purportedly mailed a letter
to petitioner’s address stating NCPL had lent the Talmages
$4,856,172 for the development of the Rivercliff property
pursuant to the January 25, 1999, loan agreement.8
On January 15, 2001, Mr. Seki purportedly mailed a letter to
Kumiko Talmage, which stated:
Dear Kumiko-san,
I am again writing in follow-up to my notice to you of
the 14th of November 2000. As of the date of this
letter, I have not yet received any response from you
(either directly or via Ronald) regarding my call for
security on the very sizable loan I have extended to
you and Ronald for your Oregon property. I thus regard
your lack of response as a negative and as your having
the intent to obstruct my lawful right to security on
the said loan.
8 The $4,856,171.94 includes only the amounts NCPL wire
transferred to SSI and does not include the $249,193 TPPL wire
transferred to SSI in 1998 or any amounts petitioner may have
paid SSI directly.
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Last modified: March 27, 2008