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was also engaged in law practice and other activities prior to
that time. Petitioner was on the board of directors of a bank
known as Schertz Bank & Trust Co. from 1975 through 1987, and at
one time owned a controlling interest and was a director in said
bank. Petitioner maintained a number of bank accounts at the
Schertz Bank in the names of himself, his law partners, his wife,
or in similar names showing involvement in professional activity.
Petitioner also maintained bank accounts in at least seven other
banks, which were likewise titled either in the name of himself,
his wife, his partners, or associated interests, and over which
he had control. The principal account which petitioner
maintained at the Schertz Bank, however, known as the "Leonard
Leighton, Attorney at Law", account, had checks drawn by both
petitioner or his wife, and was the depositary of many funds.
Using friends, and sometimes clients, as sources, from 1972
through 1988, petitioner promoted and managed more than forty
real estate ventures, sometimes called "joint ventures",
involving raw land, apartment complexes, and motels. His friends
and clients were the principal sources of investment in these
ventures, which were composed of different individuals who
invested varying amounts of money in the various joint ventures.
Petitioner drew all necessary joint venture agreements and
conducted all necessary negotiations regarding purchases and
sales in these ventures. No two joint ventures had identical
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