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During 1991, petitioner paid a total of $472.75 to Laser
Devices, Inc., for merchandise for his residence.
During 1991, petitioner paid $1,363.61 to Pittsburgh Florist
for the installation and maintenance of shrubbery and plants at
the Babcock building.
In May 1991, petitioner purchased a Rinker boat from Chet
Aleks Yamaha & Marine (Chet Aleks). The purchase price of the
Rinker boat, including sales tax, document preparation fees,
registration fees, and a temporary license fee totaled $66,819.
Joseph C. and Bertha M. Piole are petitioner's parents.
Before purchasing the Rinker boat, petitioner transferred $19,000
in cash to his parents' checking account. On May 10, 1991, M.
Richard Mellon (Mellon), an attorney who was assisting petitioner
in the purchase of the boat, tendered to Chet Aleks a check in
the amount of $6,300, representing petitioner's downpayment on
the boat. On or about May 13, 1991, petitioner paid Chet Aleks a
total of $61,519, consisting of $7,019 in cash, petitioner's
check in the amount of $11,500, Wilderness Taxidermy's check in
the amount of $16,500, a check in the amount of $19,000 made
payable to Chet Aleks and drawn on his parents' account, and a
check in the amount of $7,500 made payable to Chet Aleks drawn on
Mellon's account. Petitioner subsequently reimbursed Mellon by
giving him $7,500 in cash. Chet Aleks applied $60,519 of the
$61,519 to pay off the balance due on the Rinker boat. Chet
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