Charles L. Fields and Barbara S. Fields - Page 11

                                       - 11 -                                         
          August 1980 through July 1981.  On August 8, 1980, ABL agreed               
          with CAI to buy the same oil at the same price plus a commission            
          of 25 cents per barrel.  Ashland arranged the terms for shipping            
          the oil, it nominated the vessels used for lifting the oil, and             
          it set the mode of payment for the oil.  Petitioner and Dr. Young           
          arranged for ABL's purchase of the oil, and ABL paid them for               
          their services by paying CAI the spread between the back-to-back            
          contracts.  Commissions for the shipments under the August                  
          contracts totaled $1,064,424.  The last shipment under the August           
          contracts was on March 3, 1981.                                             
               On January 1, 1981, CAI and ABL entered into a contract for            
          the monthly purchase and sale of approximately 70,000 metric tons           
          of oil for the 7-month period ended July 31, 1981.  ABL paid the            
          set price directly to SNH, and ABL took delivery of the oil                 
          directly from SNH.11  ABL paid the per-barrel commissions                   
          directly to CAI.  Petitioner and Dr. Young arranged for ABL's               
          purchase of the oil, and ABL paid them for their services by                
          paying CAI the spread between the back-to-back contracts.                   
               ABL paid commissions to CAI by check.12  All of these checks           
          were payable to CAI and deposited into CAI's checking account               
          (the C account) at N.T. Butterfield & Son Bank (Bank) in Bermuda.           

               11 ABL put a provision in the back-to-back contracts that              
          allowed it to pay SNH directly for the oil to ensure itself that            
          the oil was paid for.                                                       
               12 All of the commissions were due to the efforts of                   
          petitioner and Dr. Young.                                                   




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