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make it; make it." Shortly thereafter, Jack Ham telephoned
Nelson, who referred him to McDonald. In late August 1978,
Commerce Bank approved the construction loan. For petitioner's
assistance in procuring the loan, Jack Ham believed he owed a
finder's fee.
When later interviewed by respondent's agents, petitioner
denied having played any role in helping Jack Ham and his
associates obtain the $2.5 million in financing for the Royal
Arms project.
The Oil Partnership Sale Scheme
Before petitioner left office in January of 1979, he needed
to pay off his oil partnership debt at Commerce Bank because he
and Mrs. Blanton wanted to buy a house in Nashville. They did
not have enough money for a downpayment, and petitioner knew that
in order to sign a note for the entire purchase price of a house
he "would have to lower [his] liabilities."
Sometime in the fall or winter of 1978, petitioner contacted
Jack Ham, who owed him money for the liquor license and the
construction loan finder's fee. Petitioner told him that he
could have the oil partnership interest if he paid off
approximately $38,000 in debt that petitioner owed Commerce Bank.
Jack Ham agreed.
Jack Ham had previously invested in oil wells. As he
indicated, however, during a deposition taken before petitioner's
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