Mark N. and Marla R. Kantor - Page 6

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            Co., Mark also became increasingly anxious about being fired for                          
            abusing drugs.                                                                            
                  In July 1983, The First Boston Corporation (First Boston)                           
            offered Mark a position in its restricted stock group, which was                          
            then expanding.  Mark accepted the offer as a solution to his                             
            perceived problems at Goldman, Sachs & Co., despite his fears of                          
            accepting the same sort of demanding job that he had voluntarily                          
            abandoned just 2 years earlier.                                                           
                  Mark took his drug abuse habit to First Boston.  His                                
            behavior became even more erratic.  Three days after reporting to                         
            work, Mark missed 2 days because he was taking drugs.                                     
            Thereafter, he canceled a business trip, with the false excuse                            
            that his mother had broken her arm.  On another occasion, after                           
            he had been missing for 2 days, Marla found him at the train                              
            station, asleep in the back of his Jeep.  In 1984, Mark went to                           
            Harrah's Casino in Atlantic City for a second binge of illegal                            
            drug use.  During visits to Harrah's in 1982 and 1984, Mark wrote                         
            checks totaling $12,600.  Despite this erratic behavior, First                            
            Boston earned commissions in the range of $3.5 million and $5.5                           
            million on transactions that Mark executed in 1984 and 1985.                              
            Mark continued as an employee at First Boston until 1989.                                 
            2.  Petitioners' Lifestyle and Financial Transactions                                     
                  Despite frequent drug-related absenteeism, Mark focused on                          
            keeping his job during the years at issue, first at Goldman,                              
            Sachs & Co. and then at First Boston.  Mark's earnings, from                              




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