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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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