J.J. Zand - Page 65

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          Dutton, who at that time worked for Deloitte, Haskins and Sells.            
          Although no return preparer's name appears on petitioners' 1978             
          and 1979 returns, Mr. Dutton was involved in their preparation.             
          An amended return for the year 1979 filed April 4, 1983, was                
          prepared by Santen, Santen & Hughes Co., LPA.  Deloitte, Haskins            
          & Sells prepared the 1980 and 1981 Forms 1040 and 1040X.                    
                                   E. Bank Accounts                                   
               There were a significant number of bank accounts under                 
          petitioner's control or into which his funds were deposited                 
          during the years at issue.  The accounts in the names of either             
          CTC or petitioner were located at First National City Bank,                 
          London; City National Bank & Trust Company, Columbus, Ohio; Bank            
          One of Columbus, Ohio; Raiffeisen Bank, Kitzbuhel, Austria; Bank            
          of America, New York; and First National City Bank, Channel                 
          Island.  The accounts in the name of Diesel Power were located at           
          City National Bank of Columbus, Ohio; Bank of Teheran, Iran;                
          First National City Bank, Geneva, Switzerland; First National               
          City Bank, New York; Bank of America, New York; Citibank, Channel           
          Island; and Banque de Paris Et Des Pays-Bas (Suisse) S.A. (Banque           
          de Paris), Geneva, Switzerland.  An account in the name of WHIP             
          was located at Barclays Bank, Freeport, Bahamas.  An account in             
          the name of All Patents was located at Banque de Paris, Geneva,             
          Switzerland.  An account in the name of IGOS was located at City            
          National Bank & Trust Company, Columbus, Ohio.  An account in the           





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