Walton A. Sutherland - Page 9

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          08-058077-2 (the second account).  The second account was titled            
          similarly to the first account, but carried Hester's Social                 
          Security number.  Petitioner was authorized to make withdrawals             
          from the second account.  Between February 4, 1988, and                     
          November 28, 1990, petitioner withdrew at least $518,000 from the           
          second account.                                                             
          Gambling in Atlantic City                                                   
               During 1987, 1988, and 1989, petitioner traveled to Atlantic           
          City, New Jersey, to gamble at at least four casinos:  Caesars              
          Atlantic City, Tropworld, Ballys Park Place Casino, and Trump               
          Casino Hotel.  Hester, at times, accompanied petitioner to                  
          Atlantic City.  At each casino, petitioner bought chips, with               
          which to make bets (known as "buying in").  Additionally, at one            
          casino, Tropworld, petitioner maintained a front money account              
          from January 1988 through at least July 1990.  A front money                
          account allows a patron to put money on deposit with the casino             
          and draw on the deposit at the gaming tables so the patron does             
          not have to carry around cash.  The following represents                    
          petitioner's gambling history at the casinos during 1987, 1988,             
          and 1989:                                                                   
               1987           Caesars   Tropworld    Trump   Ballys                   
               Buying                                                                 
               in             $0        $22,000     $0      $0                        
               Front money                                                            
               deposit        0          0        0         0                         
                    Total     $0        $22,000     $0      $0                        
               ------------------------------------------------------                 
                1988          Caesars   Tropworld    Trump    Ballys                  




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