Michael J. Fitzpatrick - Page 8

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          approvals.  Petitioner was instrumental in opening an account for           
          Pares Y Nones, S.A., into which the $50,000 was deposited.  In              
          connection with the purchase of a 71-foot Bermuda ketch by Banba            
          Associates on December 15, 1982, petitioner directed a Panamanian           
          attorney to wire $42,500 from the Pares Y Nones, S.A. account.              
          Approximately 1 month prior to directing this disbursement,                 
          petitioner had obtained a survey report on the ketch.  Petitioner           
          was the signatory on behalf of the seller.                                  
               During 1982, Dwyer Construction Co. made repairs and                   
          renovations to petitioner's residence.  The renovations were                
          first discussed by Finley, Romeyn, and petitioner at the Long               
          Wharf loan closing.  Petitioner requested that a Jacuzzi be                 
          installed in his house and that Landing send some of its                    
          construction workers to his house to do renovations.  Landing               
          made payments of $6,087 to Dwyer and Dwyer Construction Co. in              
          connection with the renovations.                                            
               On November 2 and 29, 1984, Romeyn wrote to petitioner and             
          demanded payment from him initially in the amount of $35,000 and            
          thereafter in the amount of $45,000.  These demands were made by            
          Romeyn under the threat that, if the money was not forthcoming,             
          the Internal Revenue Service would be advised of petitioner's               
          involvement in the R&S account and the Pares Y Nones, S.A.                  
          account.  Petitioner never complied with either of Romeyn's                 

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