Robert Libutti - Page 5

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          sole discretion, as opposed to a direct application of this                 
          formula.  Trump's payment of the comps to petitioner was                    
          discretionary.                                                              
               A summary of petitioner’s comps is as follows:                         
                         1987                                                         
                    Automobiles.................... $319,300                          
                    Vacations......................   48,778                          
                    Jewelry........................   75,200                          
          443,278                                                                     
                         1988                                                         
                    Automobiles and accessories....  872,920                          
                    Vacations......................   55,560                          
                    Jewelry........................   46,512                          
          974,992                                                                     
                         1989                                                         
                    Automobiles and accessories....  806,858                          
                    Premium champagne..............   40,020                          
                    Entertainment tickets..........  279,978                          
                                                  1,126,856                           
               The automobiles and accessories included five Rolls Royces             
          with an aggregate value of $916,300, three Ferraris with an                 
          aggregate value of $731,400 (exclusive of additional accessories            
          of $14,875), one Bentley Corniche valued at $212,000 (exclusive             
          of a $1,890 phone installed therein), one Mercedes Benz valued at           
          $60,583, automobile repairs of $12,740, a $14,310 payment by                
          Trump so that petitioner could trade a Bentley for a Rolls, and a           
          $34,980 payment by Trump so that petitioner could trade a Bentley           
          Turbo for a Bentley Corniche.  The vacations included five                  
          European vacations with an average value of $17,568 and one                 




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