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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Cleveland, Ohio, at the time he filed his
petition. He is the father of five children. His fifth child
was born in 1987.
I. Petitioner's Assets and Financial Activities
Petitioner owns and manages real estate. Between 1978 and
1983, he purchased four properties for a total of $111,000. He
operates three of these properties as rental properties and uses
the fourth as his personal residence. In 1981, he transferred
the title to his personal residence to his 10-year-old daughter.
He continued, however, to pay the mortgage, real estate taxes,
and insurance on the property.
Petitioner maintained 16 bank accounts with aggregate year-
end balances of $12,252.81, $42,642.70, $153,060.80, and
$84,595.46 in 1984, 1985, 1986, and 1987, respectively. In
addition, petitioner held a money market account in trust for his
children and owned two certificates of deposit. On January 1,
1984, the money market account had a balance of $132,538.33.
Petitioner deposited in the money market account an additional
$82,392.38 in 1984 and $45,100 in 1985. On March 1, 1986,
petitioner withdrew $281,294.86 from the money market account,
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