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With respect to the Florida venture, Mr. Harrison traveled
to the Florida Keys 1-1/2 to 2 days with members of the
International Recoveries group. Petitioner did not participate
in the group's exploration at sea beyond observing the boats
while they were docked. This operation was in progress when
petitioner decided to invest; petitioner therefore went to
Florida only to observe the operations and speak with the other
members of International Recoveries. No treasure or anything of
value was recovered as part of the Florida venture. After the
unsuccessful Florida operation, petitioner had questions
regarding the profitability of this business. Petitioner decided
to continue with this venture after discussions with Mr. Tillman.
The International Recoveries group next traveled to
Louisiana to search for a sunken galleon called the Palamar.
Petitioner invited Mr. Saldivar to join the venture in its
search. Mr. Saldivar owned an equipment company in Tucson,
Arizona. Petitioner telephoned Mr. Saldivar and asked him to go
along on the Louisiana trip in 1989, and Mr. Saldivar agreed to
join the expedition. Mr. Saldivar was recruited for this trip
because he had the ability to make cages that would protect
divers against sharks and other underwater dangers. These metal
cages containing the divers would be lowered by crane from the
ship. The cost of construction would be paid by petitioner who
agreed to reimburse Mr. Saldivar for any expenses incurred in
this project. Mr. Saldivar also made an air lift. The air lift
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