Leonard Ray Blanton and Betty Blanton - Page 10

                                                - 10 -                                                  
            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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