Terence M. Bennett - Page 3

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            are incorporated herein by this reference.  Petitioner resided in                           
            Rochester, New Hampshire, at the time he filed his petition.                                
                  Petitioner is a physician who received his medical degree                             
            from Harvard Medical School in 1964.  Petitioner and his former                             
            wife Linda Bennett (Linda) were married on June 1, 1964.                                    
                  In 1973, petitioner moved to Saudi Arabia where he worked as                          
            a physician for Raytheon.  From 1974 to 1981, petitioner operated                           
            a medical clinic in Jeddah, Saudi Arabia.  While in Saudi Arabia,                           
            petitioner became acquainted with Abdul Aziz Ben-Jabr (Abdul),                              
            whom he treated for hepatitis, and other members of the Ben-Jabr                            
            family.  Abdul died in late 1977 or early 1978.                                             

            Petitioner's Acquisition and Sale of the Automobiles in Issue                               

                  Petitioner has collected antique automobiles since his                                
            youth.  At the time he moved to Saudi Arabia, petitioner had a                              
            collection of approximately 60 antique automobiles, which he                                
            stored in Gloucester and Rowley, Massachusetts.  Petitioner                                 
            continued to pursue this hobby while in Saudi Arabia.                                       
                  On or about August 18, 1978, petitioner purchased a 1937                              
            Mercedes Benz 540-K, Serial No. 130941, from Earl Blakely for                               
            $60,000.  The bill of sale dated August 18, 1978, listed                                    
            petitioner as the buyer of the automobile.2 In November 1978,                               


                  2Par. 6 of the stipulation of facts lists the automobile as                           
            a 1937 Mercedes 540-K.  The bill of sale indicates that the                                 
            automobile was a 1936 Mercedes 540-K.  We assume this to be an                              
                                                                          (continued...)                




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