Robert D. Grossman, Jr. - Page 10

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          During the years in issue, Ben practiced law in Texas.  He is               
          also a registered stockbroker and a consolidated life                       
          underwriter.  In 1984, Ben ran for county attorney in Neuces                
          County, Texas.                                                              
               Petitioner, Betsy, and Ben grew up in the Miami, Florida,              
          area.  Petitioner and Betsy went to the same high school.                   
          Petitioner and Ben have known one another since they were                   
          children, and petitioner was best man at Ben’s wedding.                     
          Petitioner’s parents also lived in the Miami area during some               
          part of the years in issue.                                                 
                                  Sley Corporations                                   
          Background                                                                  
               Harry formed a number of corporations to conduct parking               
          lot, garage, and real estate investment businesses in more than             
          60 locations in Philadelphia, Pennsylvania.  In general, these              
          corporations, hereinafter sometimes referred to collectively as             
          the Sley Corporations, owned and operated properties at different           
          locations.                                                                  
               The Sley Corporations’ businesses and offices originally               
          were located in Philadelphia; they remained in Philadelphia,                
          until the fall of 1980, when the offices were moved to                      
          Washington, D.C.  The Sley Corporations include Brine Corp.,                
          Girard Holding Co., Inc., Markette Corp. (hereinafter sometimes             
          referred to as Markette), Parkette Corp. (hereinafter sometimes             





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