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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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