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Bank in Stockholm, Sweden, to Bank Julius Baer & Co. (Julius
Baer) of London, England. The funds were credited to Julius
Baer's account (No. 04-056-925) at Banker's Trust Co. in New
York, and were available on or about July 7, 1988.
On or about July 8, 1988, petitioner sold the five
automobiles for $3 million to Mr. Harley who was acting on behalf
of Winkeleigh Garage, Ltd., of London, England.4 Petitioner
signed the bill of sale for each automobile, thereby covenanting
to the buyer that he was the lawful owner.5 Mr. Harley
subsequently wrote the sale price for each automobile on the bill
of sale based upon his opinion of the automobile's market value.6
Petitioner also transferred to Mr. Harley the certificate of
title for each automobile except the Lagonda LG45 Repead.
On July 18, 1988, $453,375 was wired from the Julius Baer
account (No. 04-056-925) at Banker's Trust Co. in New York, to
4At the time of the transaction, Mr. Harley was a director
and major shareholder of Winkeleigh Garage, Ltd.
5Petitioner never represented to Mr. Harley that he was not
the owner of the automobiles.
6Mr. Harley attributed the following sales prices to the
automobiles:
Automobile Sale Price
1937 Mercedes 540-K $550,000
1929 Bentley Tourer 250,000
1936 500K Mercedes 1,500,000
1932 Mayback Zepplin 550,000
Lagonda LG45 Repead 150,000
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