Julian P. Kornfeld - Page 4

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            (Prudential Bache) or from Prudential Bache's own inventory of                                
            bonds.  Prudential Bache confirmed each purchase involved herein                              
            by a confirmation slip addressed to the Julian P. Kornfeld Life                               
            Estate, with an Oklahoma City address.                                                        
                  After the purchases, but before the closing dates,                                      
            petitioner would calculate the value of the respective interests                              
            in the bonds that he and the other parties were acquiring.  The                               
            Exhibits A executed by the parties were dated the same day as the                             
            Prudential Bache confirmations.  Petitioner's calculations were                               
            based upon the actuarial values published by the Internal Revenue                             
            Service.  The allocations reflected in such calculations are not                              
            disputed by respondent.                                                                       
                  Based upon the aforesaid calculations, petitioner would                                 
            furnish Nancy, Meredith, and Permenter with the amounts indicated                             
            as their share of the purchase price.  This would be accomplished                             
            either by check or wire transfer to the respective bank accounts                              
            before the closing date of the purchase.  During the years in                                 
            issue, Nancy's bank account was in Minneapolis, Minnesota,                                    
            Meredith's bank account was in Los Angeles, California, and                                   
            Permenter's in Oklahoma City, Oklahoma.                                                       
                  With respect to every purchase, the amounts furnished by                                
            petitioner were deposited in the bank accounts.  Thereafter, and                              
            before the closing dates, Nancy, Meredith, and Permenter issued                               
            their separate checks to Prudential Bache in the amounts                                      
            reflected in petitioner's calculations as allocable to the                                    




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