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the Indian Head Bank in Portsmouth, New Hampshire, in
satisfaction of an outstanding mortgage on property that
petitioner owned in Maine.
Petitioner's Divorce
Petitioner and Linda Bennett began to live apart sometime
around November 1987. In the spring of 1988, petitioner
compiled, in contemplation of divorce, a three-page list of the
couple's marital assets and their estimated values. Included on
this list were the five automobiles later sold to Mr. Harley on
or about July 8, 1988.7 On July 9, 1988, petitioner informed
Linda that he had sold these automobiles in order to finance the
couple's divorce settlement. Linda then wrote "sold" beside the
listing for each automobile.
On or about September 7, 1988, petitioner paid $2.5 million
to Linda in connection with the settlement of their divorce.
This money was paid by a check dated September 7, 1988, drawn on
the account of Banque de l'Etat de Fribourg at the New York
Branch of Credit Lyonnais Bank.
On September 15, 1988, petitioner filed with the Superior
Court of the State of New Hampshire a document entitled "Support
7The stipulation of facts and exhibits contain slight
discrepancies regarding the model year of petitioner's
automobiles. However, there is no question that the automobiles
sold to Mr. Harley were the same automobiles that were included
on the list of marital assets that petitioner and Linda Bennett
compiled in contemplation of their divorce.
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