Frederick G. Harrison, Sr. and Estate of Catherine Harrison, Deceased - Page 7

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          into a joint venture with International Recoveries, Inc., based             
          on business plans and maps that were shown to him as well as his            
          evaluation of the other investors and Mr. Tillman's expertise in            
          the area.                                                                   
               When assessing potential transactions for his trucking and             
          waste management businesses, Mr. Harrison generally sought legal            
          assistance.  Mr. Harrison did not seek legal assistance with                
          respect to his dealings with International Recoveries.                      
               Petitioner went to libraries and read books and other                  
          publications regarding treasure hunting.  The materials                     
          petitioner referred to did not discuss the cost of treasure                 
          salvaging or how to make a treasure hunt economically feasible.             
               Petitioner set no specific budget with respect to his gold             
          mining and treasure hunting activity.  Mr. Harrison was invited             
          to join International Recoveries in its ongoing exploration for             
          sunken treasures for an investment of $50,000.  For this                    
          investment, petitioner was to share in any recovery.  Petitioner            
          did not agree to the first offer to join International Recoveries           
          and negotiated a better deal than that originally presented.                
               During 1989, the International Recoveries group participated           
          in three primary expeditions with petitioner.  The group was                
          involved in operations off the Florida Keys, off the coast of               
          Louisiana near the base of the Mississippi River, and on a farm             
          in Goliad, Texas.                                                           






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