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petitioner purchased a 1929 Bentley Tourer Speed Six, Serial No.
K2683, from Herbert A. Schoenfeld, Sr., for $40,000. In a letter
dated April 16, 1979, Mr. Schoenfeld released title and interest
in the automobile to petitioner.
During late 1979 or early 1980, petitioner purchased a 1936
500K Mercedes Roadster, Serial No. 130857, from Carlisle L.
Marshall for $100,000. Mr. Marshall transferred the automobile's
Motor Vehicle Certificate of Title (State of Florida) to
petitioner on or about January 3, 1980.3
At some point during the late 1970's or early 1980's,
petitioner also purchased a 1932 Mayback Zepplin, Serial No.
1388, and a Lagonda LG45 Repead, Serial No. 12226. The amount
petitioner paid for each of these automobiles is unknown.
Petitioner retained possession and control over the five
previously mentioned automobiles until their sale in 1988. In a
letter dated June 5, 1988, petitioner offered to sell these five
automobiles to Nicholas Harley for a total sales price of $3
million. Pursuant to petitioner's instructions, on or about July
6, 1988, Mr. Harley wire transferred $3 million from the Gota
2(...continued)
error and will follow the year as indicated in the stipulation of
the parties.
3Par. 5 of the stipulation of facts lists the automobile as
a 1936 500K Mercedes Roadster. The Motor Vehicle Certificate of
Title (State of Florida) indicates that this automobile was a
1937 model. We assume this to be an error and will follow the
year indicated in the stipulation of the parties.
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