Charles L. Fields and Barbara S. Fields - Page 13

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          3.  Finley Kumble's Legal Advice                                            
               On September 26, 1980, attorneys from Finley Kumble met with           
          petitioner and Dr. Young in Washington, D.C.  Petitioner and Dr.            
          Young believed that they had a tax problem with respect to funds            
          brought from Bermuda into the United States, and they requested             
          assistance from Finley Kumble on this problem.  Petitioner and              
          Dr. Young informed the attorneys that they (petitioner and                  
          Dr. Young) had drawn approximately $90,000 on CAI's C account for           
          reasons that included the payment of their personal creditors in            
          the United States.  Petitioner and Dr. Young produced checks                
          payable to their creditors in the total amount of $75,000 which             
          had not been transmitted or cashed.15  Petitioner and Dr. Young             
          later voided all of these untransmitted and uncashed checks at a            
          subsequent meeting with Finley Kumble on October 2, 1980.                   
               On October 10, 1980, attorneys from Finley Kumble met with             
          petitioner and Dr. Young to discuss primarily the tax issues                
          connected with petitioner and Dr. Young's receipt of the funds.             
          Finley Kumble recommended that petitioner and Dr. Young ignore              
          the existence of CAI and report the commissions as income.                  




               15 By September 1990, petitioner and Dr. Young had actually            
          withdrawn almost $400,000 from the C account, in addition to the            
          $75,000 of uncashed drafts, most of which was attributable to               
          petitioner.                                                                 






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