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1. Dr. Bennett told me in July or August of 1988 that
he had sold five antique automobiles for the sum of
Three Million Dollars.
This was not surprising. Previously in my association
with Dr. Bennett he had sold other cars and told me of
the details, including the cars sold in 1987 to pay off
the 1987 assessment on his 1985 return.
There was no new behaviour[sic] here, and no surprise.
Only the sum of money was in any way unusual.
2. Dr. Bennett said that the cars belonged to the
estate of a deceased patient from Saudi Arabia. (Abdul
Aziz Ben Jabr)
3. Dr. Bennett said that the cars had been sold to a
European buyer through some kind of an English broker,
and that the money had been paid into the control of
the Ben Jabr family at their bank, that he had not
handled any of the money at the time of the sale.
4. Dr. Bennett said that he had arranged to borrow
almost all of the money back from the Ben Jabrs to
finance his divorce and pay off a mortgage at the
Indian Head Bank. These transfers were effected by the
Saudis via a Bank Check, and a bank to bank direct
transfer, all completely aboveboard. He got divorced,
and the Bank got their money.
5. I told Dr. Bennett that, in my opinion, this was
not a taxable transaction.
6. Accordingly it was not reported on his 1988 tax
return.
7. Dr. Bennett discussed this sale/loan with me at the
time it occurred. He was up front about the
transaction, and truthful, to the best of my knowledge.
There is no mystery here. This is not a taxable
transaction, to the best of my knowledge.
8. That the IRS is trying to argue that in 1993 the
value of Dr. Bennett's holdings is not enough to repay
the loans is a lame argument.
9. In 1988 Dr. Bennett's real estate holdings alone
were worth several times the amount borrowed, and he
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