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            acquainted, including an accountant, an attorney, and a                                    
            communications consultant, to apprise Mr. Mussman of potential                             
            opportunities to acquire other local telephone companies.  On the                          
            record presented in the instant cases, it is not clear whether                             
            Mr. Mussman intended and planned to have NITCO or individual                               
            members of the Mussman family ultimately acquire other telephone                           
            companies.                                                                                 
                  In 1990, NITCO contacted two local telephone companies about                         
            the possibility of acquiring them.  One telephone company replied                          
            that it was not for sale; the other company never responded to                             
            NITCO's inquiry.                                                                           
                  Additionally, in 1990, Rhys visited another local telephone                          
            company located in Tennessee to examine its operations and to                              
            discuss its possible purchase.  Rhys' trip took place after the                            
            IRS’ commencement of the examinations that resulted in the                                 
            instant cases.                                                                             
                  From 1987 through the time of trial, NITCO did not enter                             
            into a contract to purchase another local telephone company.                               
                      I.  NITCO's Provision of Financial Assistance to                                 
                  Mr. Mussman's Sons and Various Companies the Sons Owned                              
            Rhys and Northwestern Indiana CATV, Inc.                                                   
                  Prior to 1983, Northwestern Indiana CATV, Inc. (NICATV), a                           
            corporation that Rhys owned, applied for and was issued a license                          
            by the FCC to offer cable television services in certain areas in                          
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