Walter L. Medlin - Page 54

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          his agent filed with the Osceola County Recorders Office paid               
          documentary stamp taxes of only $.50, reflecting a reported sales           
          price of less than $100.                                                    
               Petitioner maintained the following bank accounts during the           
          tax years at issue:                                                         
               Bank Name                Account Number      Account Name              
          Freedom Savings and Loan      32-480-9       Walter L. Medlin               
          (formerly Com Bank)           Trust Account 1                               
          Tucker State Bank        1089234             Walter L. Medlin               
          Tucker State Bank             18066            Walter L. Medlin             
                                                       Trust Account 1                
                                                                                     
          The accounts titled “Trust Account 1” were actually petitioner’s            
          personal bank accounts.  Petitioner was also the beneficiary of a           
          Cayman Islands trust account at Washington International Bank and           
          Trust, Ltd., which he had funded.                                           
               On a financial statement dated November 15, 1985, petitioner           
          represented that he had a net worth of $10,822,260, and he valued           
          his automobile collection at $2,717,000.  On a financial                    
          statement dated June 1, 1988, petitioner represented that he had            
          a net worth of $7,121,800.  On a financial statement dated                  
          September 20, 1989, petitioner represented that he had a net                
          worth of $8,837,000.11                                                      
               Thomas Brooks, a certified public accountant, prepared                 
          petitioner’s tax returns for the 1977-1982 tax years.  Petitioner           
          provided spreadsheets of his income and expenses to Mr. Brooks              

               11The financial statements dated June 1, 1988, and Sept. 20,           
          1989, do not include a listing for petitioner’s automobile                  
          collection.                                                                 




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