8
acres of property owned by the Dennis Horton Trust 101 in
Clermont, Florida. The land contained citrus groves when Bob
Wade bought an interest in it. There was no citrus production
from the property after a freeze in 1983. After citrus
production ceased, Wade sold dirt from the property to the State
of Florida for highway construction.
Petitioner invested in the Dennis Horton Trust 101 on
September 11, 1984. The Dennis Horton Trust 101 balance sheet
for December 31, 1989, showed that the trust had given petitioner
notes payable in the amount of $2,211,268.84.
Petitioner occasionally visited the dirt fill operation with
Wade, but did not do any work for it in 1988 or 1989. Wade
obtained the permits, arranged for design work, and did all of
the other work for the dirt fill operation. Petitioner spent no
more than 30 hours at the dirt fill site in 1988 and 1989.
F. Petitioners' Family Trips and Other Family Expenses
Petitioner often took his family on expensive trips. They
went to Vietnam, Australia, New Zealand, South Africa, Hawaii,
Europe, Russia, China, and Hong Kong. Petitioner took Gail
Bohannon to Australia, New Zealand, Samoa, Fiji, and Hawaii for
36 days in 1972. Sometime between 1972 and 1990, he took Scott
Bohannon and Scott's girlfriend to China for a month. He paid for
Scott's and Scott's girlfriend's trip to South Africa. He also
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