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account for his benefit. Petitioner and Dr. Young withdrew
$247,788 from the C account for the benefit of both; respondent
determined that half of this amount ($123,894) was attributable
to petitioner.
Petitioner borrowed $25,000 from the Bank on December 19,
1980, and $10,000 on October 1, 1981. Petitioner paid off the
loans with funds from his account at Citibank, and with funds
from the C account, the set-off account, and the A account.
Petitioner caused $31,819 to be withdrawn from the set-off
account and applied to his loans at the Bank.
Petitioners used checks drawn on CAI's C account to pay for
more than $55,000 of renovation to their home in Rye, New York,
in 1980 and 1981. They used checks drawn from CAI's C account to
pay for more than $9,000 in landscaping at that home in 1980.
They used checks drawn from the C account to pay for more than
$100,000 in interior decoration in 1980 and 1981. They used
checks drawn on CAI's C account to pay for summer programs for
their children. They used a check drawn on CAI's C account to
pay for legal services incurred in purchasing undeveloped land in
1980 for more than $100,000.16 Mrs. Fields used checks drawn on
CAI's C account to purchase more than $5,000 of china.
16 Petitioners planned to spend an additional $217,000 to
build a vacation home, two tennis courts, and a pool on the land,
but they ended up selling the undeveloped land for $450,000.
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