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claiming $12,313 attributable to Oceanic Leasing XXXV, using the
same EIN.
Latta, who, along with Willner, executed the agreement
referring to Oceanic Leasing XXXV, claimed Oceanic Leasing losses
using EIN 94-2870681 on her individual return for 1986 without
reference to "XXXV". The Form 1065 filed by Hardin attached a
Schedule K-1 for Latta.
Willner gave Hardin payments totaling approximately $79,000
from 1985 through 1989. Those payments included a check dated
July 26, 1988, in the amount of $10,000 payable to Oceanic
Leasing, without any Roman numeral designation. Willner received
Oceanic Leasing checks in the amounts set forth below and bearing
the indicated notations in the lower left corner:
Date Amount Notation
July 22, 1988 $20,701.42 Ocean. 35
Oct. 31, 1988 8,505.85 OL 35
Feb.6, 1989 11,462,57 OL 35
May 11, 1989 11,452.57 #35
July 24, 1989 1,215.00 #006
July 27, 1989 5,600.00 #035
Nov. 7, 1989 5,600.00 035
Nov. 13, 1989 5,597.47 None
Feb. 2, 1990 11,452.47 #035
Apr. 25, 1990 8,195.97 #035
All of the checks bore the name and Sausalito address of Oceanic
Leasing and were written on the same bank account.
Willner believed that Hardin was completely in control of
running the business of the partnerships and acquiesced in
Hardin's conduct with respect to the partnerships.
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