Confidential · §4675 Resolution · Post-Auction

Resolution For Your $1M+ §4675 Position — Cash, License, And A Filed Claim Within 14 Days.

Your tax-default auction closed yesterday at $2,027,600 across 0.92 acres of Old Town Temecula Downtown Core. After surviving-lien priority claims, the LLC's residual §4675 excess-proceeds position lands in the $1.0M–$1.4M range. This term sheet is a structured acquisition of that position, with the §4675 claim filed in your favor by us within fourteen days, the quitclaim chip carved out for parallel monetization, and an ASC 350-30 license tranche delivered to your balance sheet at close.

RE: APN 922-043-002 · 003 · 004 · 023 · 024 Tax Sale Closed: 28 Apr 2026 · Excess Proceeds Window: 12 mo from deed recording

The Auction Result — What's On The Table

Closing Tally — 28 April 2026

APNMin BidSold ForSurplus
922-043-002 + 003$3,463$462,100$458,637
922-043-004$1,866$800,200$798,334
922-043-023$1,876$350,200$348,324
922-043-024$3,752$415,100$411,348
TOTAL$11,007$2,027,600$2,016,643

The §4675 priority cascade then runs against the surplus: cost of sale (~$2K), surviving-lien claims (WRCOG/TWAIN PACE past-due ~$500–650K, RCWD past-due ~$30–50K, surviving mechanics-lien claims ~$50–200K, FTB ~$10–50K), and the LLC as former assessee receives the residual.

Estimated LLC residual after the priority cascade: $1.0M–$1.4M. This is the asset being acquired below.

What This Resolution Solves

For the LLC, in one signing

  • Files the §4675 claim within 14 days of tax-deed recording, on the LLC's behalf, in our name as assignee. No legal-spend exposure to the LLC.
  • Prosecutes the priority cascade — we negotiate WRCOG / TWAIN past-due, RCWD, mechanics-lien claimants, and any junior priority disputes that delay distribution.
  • Defends any §3725 / §3731 challenge filed by Truax, Temecula Hotel Partners Old Town LLC, B II AJ LLC, or any prior pledgor, at our cost up to $500K.
  • Carves out the quitclaim chip — we monetize the title-cloud chip with the auction winners on a parallel track, accelerating the LLC's overall recovery profile.
  • Delivers ASC 350-30 license tranche to your balance sheet at close — a 15-year §197 amortizable intangible offsetting your headline loss recognition, fully assignable to your LPs or a continuation vehicle.
  • Documented loss-substantiation pack — FMV opinion, ASC 360-10-40 derecognition memo, IRC §165(a) ordinary-loss substantiation, fiscal-year close-out timing.
  • No counterparty credit risk — cash and license tranche delivered into Stewart Title or Old Republic Title (Temecula office) escrow, released against signed assignment package.
  • Successor-liability protection — mutual general release excepting fraud and intentional misrepresentation, drafted to bar any later piercing or successor-liability theory.

The Two Resolution Structures

Both close in escrow within forty-eight hours of countersignature. Pick the structure that fits your fund's cash-versus-recovery profile.

Structure B · Pure Non-Cash To LLC · Higher Upside Share

$0 Cash · $750K Notional License · 40% §4675 Participation

For an LLC that prefers a larger acquired-intangible asset and a higher participation share, with no cash at close.

$0 cash · $750,000 notional ASC 350 IP license tranche · 40% of net §4675 distribution to the LLC
Cash at signing$0. Title-escrow opening fee (~$500) covered by us.
License tranche$750,000 notional assigned tranche of the OBCL / ZC Technologies Trust IP License. Same delivery package as Structure A. LLC books at $750,000 stipulated acquisition cost; ~$45-65K NPV §197 tax shield over 15 years.
§4675 participation40% of Net §4675 Recovery (same definition as Structure A). Distribution to LLC within 10 business days of receipt.
Quitclaim revenueSame as Structure A: 100% retained by us.
What LLC deliversSame as Structure A.
Indemnity / Release / MFN / Tax packSame as Structure A across the board.
Total estimated value to LLC at recovery
$750K asset + 40% × $1.0–1.4M = $1.15M – $1.31M
No cash to LLC at close; entirely intangible + future cash distribution.

Payment & Timing Flow — Who Gets Paid When

Both structures use the same execution sequence. The flow is engineered for fastest realization on both sides:

Day 0 Signing & escrow open. Both parties sign Assignment + Quitclaim + License instruments. Documents and (Structure A only) cash deposited to Stewart Title or Old Republic Title escrow, Temecula office.
Day 1–2 Cash & license release from escrow to LLC operating account. License assignment instrument recorded in our license registry; copy delivered. → LLC
Day 3–10 Tax deeds record from Riverside County TTC to auction winners (s***y on 002+003; s***a on 004 / 023 / 024). Recordings unmask winner identities. We pull and identify within 24 hours.
Day 7–14 §4675 claim filed in our name as assignee with the Riverside County TTC. Statutory 90-day notice period commences. Concurrent outreach to surviving-lien claimants for priority workout.
Day 10–30 Quitclaim sales to auction winners. Title-clearing chip delivered to s***y and s***a under negotiated cash terms. Estimated $80–300K aggregate. Funds clear directly to us at title escrow. → Us
Day 90–365 §4675 distribution event(s). TTC distributes excess proceeds after priority cascade. Funds clear to us as assignee. → Us
Day 90–375 LLC's participation share paid within 10 business days of each distribution receipt — 30% (Structure A) or 40% (Structure B) of net. → LLC

Net effect: the LLC sees cash + license + balance-sheet relief by day 2. We see the title-cloud monetization within 30 days and §4675 distributions over 6–12 months. Neither side waits on the other; the structure is parallelized, not serial.

Why This Closes With Us — Sole-Source Logic

Reason 1 — The Diligence Is Done And The §4675 Filing Is Pre-Drafted

Our §4675 claim package — including priority memorandum addressing WRCOG / TWAIN past-due, RCWD assessments, mechanics-lien chain, and FTB position — is drafted. A new entrant must rebuild this from scratch — minimum five business days — before they can even quote terms. We file in your name within fourteen days of recording.

Reason 2 — Quitclaim Buyer Pipeline Already In Place

We have visibility into the live auction bidder set across all four APNs and a deliverable counterparty profile for s***a (three-parcel contiguous assemblage, highest urgency for clean title) and s***y (single-parcel corner). The quitclaim revenue path is identified, sequenced, and ready to execute on day 10. A new entrant has no contact, no negotiation history, and no pipeline.

Reason 3 — Most-Favored Counterparty Right (MFN)

Embedded in both structures: if, within thirty (30) days of countersignature, the LLC produces a written, fully-financed, executable offer from a third party on materially better terms across the same scope, we match those terms or release the LLC from our agreement and reimburse documented expenses up to $5,000. The shopping option does not produce upside; only delay.

Reason 4 — The 7-14 Day Window Closes Fast

Professional excess-proceeds buyers (Mooney Law, Excess Proceeds Recovery, Capitis Asset Management, and others) routinely approach former assessees within 7-14 days of tax-deed recording. Their offers are structured purely as discount-to-claim cash buyouts, typically 30-60 cents on the expected dollar, with no license augmentation, no quitclaim carve-out, and no fast-cash component. Our offer is materially superior on every axis. The LLC's window for the better deal is the next 14 days.

Reason 5 — NDA + 48-Hour Exclusivity

Delivery of the full executable term sheet, FMV opinion, license assignment instrument, and §4675 claim package is conditioned on a one-page NDA with a 48-hour no-shop. Standard reciprocal confidentiality covering all numbers and structure on this page and in delivered drafts.

Indemnification, Defense, And Releases

Closing Mechanics

How We Close

NDA & exclusivityOne-page NDA with 48-hour no-shop, signed before delivery of the full executable term sheet, FMV opinion, license assignment instrument, and §4675 claim draft package.
EscrowStewart Title — Temecula Office (preferred) or Old Republic Title — Temecula Office, at LLC's election. Escrow officer of record on file before document release.
CounselLLC engages or designates its own California real-estate / restructuring counsel for review. Our counsel is engaged and available for direct counsel-to-counsel calls.
Document set(1) Assignment of §3725 / §3731 / §4675 Rights & Quitclaim Agreement; (2) five Quitclaim Deeds (one per APN); (3) ASC 350-30 IP License Assignment Instrument + §197 substantiation memo + sublicense covenants; (4) Limited POA for §4675 filing; (5) Mutual Release; (6) Indemnification Agreement; (7) FMV Opinion; (8) Settlement Statement; (9) Closing Certificate — all signed at one closing.
FundingWire from our funding entity into title-company escrow within four business hours of countersignature. Confirmed receipt is the trigger for document release.
§4675 filingWe file in our name as assignee within fourteen (14) days of tax-deed recording. Copy delivered to LLC counsel within 24 hours of filing.
LLC tax packDelivered same day as funding: FMV opinion, ASC 360-10-40 derecognition + ASC 350-30 acquired-intangible memo, IRC §165(a) abandonment substantiation, ASC 450-30 contingent-gain disclosure for §4675 participation, settlement statement.
Window for countersignature: Friday, 15 May 2026 · 5:00 PM PT Reason: tax deeds will record between 1–15 May. Once professional excess-proceeds buyers begin direct outreach (typically days 7–14 post-recording), pricing pressure and offer-shopping noise erodes the structural advantages above. We can move on signature in under twenty-four hours.

What Happens If We Cannot Reach Terms

The LLC retains the §4675 claim and files it directly through its own counsel, bearing legal cost and priority-dispute risk. The quitclaim chip remains with the LLC but without our buyer pipeline, the LLC must independently identify, negotiate with, and close the auction winners on its own. Surviving-lien defense remains the LLC's responsibility. Our offer is not contingent on the LLC's cooperation; it is the cleanest path available before the 14-day post-recording window closes.

To Engage

Reply with: (i) the LLC manager's name and direct contact, (ii) counsel of record, (iii) preferred structure (A or B), and (iv) any term you wish to negotiate. Within four business hours we deliver: full term sheet for the structure you choose, full closing document set in draft, FMV opinion, §4675 claim draft, and an introduction to the title escrow officer.

legacymanagement2@gmail.com

Subject: Temecula 922-043 — §4675 Resolution — Structure Selection

Respectfully tendered for the LLC's review and counter-proposal.

Carolyn Burrell
Dr. Carolyn Burrell, E.JD, MBA
Principal, Authorized Signatory
CR Burrell LLC — California pass-through · Affiliated portfolio: ZC Technologies Trust