Jack J. Kramer - Page 15

                                                 - 15 -                                                   
            were conduits through which large amounts of money flowed from                                
            1985 to 1987.  The record explains some, but not all, of these                                
            flows.15  Petitioner earned interest, which he did not report as                              
            income, on the deposits in these accounts during each of the 3                                
            years.  Petitioner used Barnett joint checking only for personal                              
            purposes throughout the 3-year period.                                                        
                  During this period, petitioner had no other sources of funds                            
            such as "cash hoards", except for an inheritance of $19,641 from                              
            his mother, which was deposited into Barnett money market in                                  
            November-December 1985.  In 1985, petitioner sold a house and                                 
            bought a condominium at Turnberry Isle, a luxury residential                                  
            community.  Petitioner had a mortgage loan on the condominium                                 
            with payments of approximately $2,000 per month.  He also owned a                             
            1984 Mercedes automobile.                                                                     
                  Profits from Ben's marijuana smuggling funded Fort Apache                               
            while petitioner was its president.  Petitioner disbursed funds                               
            to Fort Apache and other of Ben's enterprises from deposits that                              
            others, such as LCP Associates, made in Safra and Barnett money                               
            market.                                                                                       
                  In December 1985, Len-Ed deposited $85,000 into Safra;                                  
            $50,000 of this deposit went to two of the racing entities:                                   
            $35,000 to Apache Power Boats and $15,000 to Team Apache.  The                                
            remainder of the funds in that account rolled over into 1986.  In                             


            15The tables summarize the inflows and outflows for the                                       
            three accounts, petitioner's explanations for some of these                                   
            transactions, and respondent's concessions on others.                                         


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