Robert D. Grossman, Jr. - Page 82

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          certificates of deposit for the Sley Corporations.  For example,            
          in July 1984, petitioner told Baybrook to telephone the Mellon              
          Bank, where Markette had an investment account, and have $1                 
          million transferred from the Mellon Bank to the National                    
          Permanent Bank of Washington to buy certificates of deposit.  In            
          October 1984, petitioner told Baybrook to telephone the Mellon              
          Bank and have that bank transfer $75,000 to Markette’s checking             
          account.                                                                    
               On February 3, 1986, petitioner moved the amounts shown in             
          table 2 from the National Permanent Bank of Washington and                  
          deposited these funds into accounts he had opened in the names of           
          the Sley Corporations at the National Bank of Washington.                   
                                       Table 2                                        
                    Corporation              Amount Transferred                       
                    Markette                 $1,663,963.84                            
                    Brine Corp.              1,171,718.68                             
                    Girard Holding Co.       433,638.66                               

               On February 4, 1986, petitioner transferred by wire                    
          $432,638.66 from Girard Holding Co., Inc.’s account at the                  
          National Bank of Washington to the Mellon Bank.  On February 4 or           
          5, 1986, $1,170,718.68 was transferred by wire to Brine Corp.’s             
          account at Mellon Bank and $1,654,754.92 was transferred by wire            
          to Markette’s account at Mellon Bank.  Generally, Ben was not               
          involved in decisions to invest money in particular certificates            
          of deposit or to move money from one bank or account to another;            





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