Jack J. Kramer - Page 8

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                  The card club opened in October 1984.  By 1985, Lyon and Sam                            
            Gilbert were sending its profits, approximately $1.6 million over                             
            the course of 1985 and 1986, back to Ben through their various                                
            partnerships, such as LCP Associates.  Some of these profits                                  
            flowed into a trust account controlled by Allsworth.  Some went                               
            directly to petitioner and some went through Allsworth's trust                                
            account and then to petitioner.  At least $505,000 flowed through                             
            petitioners' joint checking account at Safra Bank in 1986.  To                                
            further conceal Ben's ownership role in the card club, some of                                
            these payments took the form of "loans" to petitioner that he                                 
            signed for on what Allsworth called "drugstore pads".                                         
                  Throughout the early 1980's, Ben competitively raced                                    
            offshore power boats, an expensive sport popular in south Florida                             
            at the time.  In 1982, Ben created an entity, Apache Racing Team,                             
            Inc., through which to conduct his boat racing and building                                   
            activities, although it was later administratively dissolved                                  
            while he was still racing and building powerboats.  Other                                     
            entities were created on an ad hoc basis.9  Allsworth was                                     
            instrumental in creating many of these entities.  Petitioner and                              
            Ben used the term "Apache" generically when referring to many of                              
            the entities connected with the offshore boat racing, and to                                  



            9Super Chief South came into existence in Aug. 1985 and was                                   
            dissolved just 15 months later in Nov. 1986.  Super Chief, Inc.,                              
            was created in Jan. 1984 and not dissolved until 1992, well after                             
            Ben, petitioner, and all of the others had been arrested, tried,                              
            and convicted on various smuggling and money laundering charges.                              



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