Charles A. Ballard - Page 8

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               On May 24, 1987, Newman moved the yacht from Lighthouse                
          Point to Mears Great Oak Landing, which is in Maryland and on the           
          Chesapeake Bay.  He returned the yacht to Lighthouse Point on               
          October 5, 1987.                                                            
               Mears Great Oak Landing is 2-1/2-hours travel time, by car,            
          from petitioner’s home in Philadelphia.                                     
               Petitioner arranged with an individual, David Hart (Hart) to           
          maintain and keep up the yacht while it was at Mears Great Oak              
          Landing.  Hart was to try and obtain charters.  At Mears Great              
          Oak Landing there was a meeting center with approximately                   
          30 rooms and a 9-hole golf course.  The yacht was the only yacht            
          for charter at Mears Great Oak Landing.  The meeting director at            
          Mears Great Oak Landing, and possibly other meeting center                  
          personnel, also were asked to try and obtain charters.                      
               Except for use made by petitioner of the yacht, there were             
          no charters of the yacht during the time it was at Mears Great              
          Oak Landing.  Petitioner made substantial use of the yacht on               
          weekends.  Petitioner paid for his use of the yacht in 1988.                
               After the yacht was returned to Florida in October 1987, no            
          use of it was made by anyone other than petitioner.                         
          Trade-In of the Yacht and Termination of Charter Business                   
               In January 1988, Ballard Marine disposed of the yacht in a             
          transaction whereby it acquired another boat, a 56-foot Hatteras            

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