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discussions with petitioner regarding the sale of these
automobiles, Mr. Gates explained as follows:
I was asking about the mechanics of the transaction,
where did it go and how did it have to go, and I was
told [by petitioner] that the cars were delivered and
the transaction took place outside the United States.
My obvious question is why does it need to be that
confusing, why does it have to be that complicated.
* * *
Q: What did Mr. Bennett say?
A: He said he did not want to--he wanted to avoid
paying the taxes. He didn't want to pay any more money
to the IRS than he had to pay. * * *
Q: Did he[petitioner] say anything with respect to the
money vis-a-vis overseas banks?
A: I recall the conversation about the transaction
taking place outside of the country and the cars being
delivered outside of the country and everything was
done outside of the country.
Q: Including the money.
A: Including the money.
Q: And the money was taken care of outside the United
States, according to Dr. Bennett, for what purpose?
A: So that he would not have to pay IRS any more taxes
than he had to pay them.
Clearly, any potential income tax consequences from the sale of
the automobiles should have been irrelevant to petitioner if he
was not the owner of the automobiles.
Petitioner's story that he purchased the five automobiles in
question for his good friend Abdul Aziz Ben-Jabr is also
inconsistent with the fact that three of the automobiles were
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