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On or about October 27, 1987, petitioners purchased shares
in the Advantage Growth Fund for $20,005 for their brokerage
account at Advest. They paid for those shares by using a trea-
surer's check that Ms. Olbres had purchased on November 3, 1987,
with part of a $45,000 withdrawal that she had made from the
Indian Head business savings account.
Certain Yachts Purchased by Petitioners
In March 1988, petitioners agreed to purchase for $172,210 a
1988 Pace yacht (Pace yacht) from Marina Harbor Corp. (Marina
Harbor). In that connection, on March 16, 1988, when the balance
of the Indian Head personal checking account was $3,958, Ms.
Olbres wrote a check for $16,000 from that account that was
payable to Marina Harbor as a downpayment for the purchase of the
Pace yacht. On March 17, 1988, petitioners withdrew $16,700 from
the Indian Head business savings account and deposited $16,000
into the Indian Head personal checking account. In June 1988,
Mr. Olbres entered into a retail installment sales agreement to
finance $133,000 of the purchase price of the Pace yacht. On
June 17, 1988, Ms. Olbres withdrew $23,210 from the 1988 Indian
Head business savings account and purchased a treasurer's check
for $23,210 payable to Marina Harbor for a further downpayment on
the Pace yacht.
In October 1988, petitioners traded in the Pace yacht in
order to purchase for $1,002,752 a 54-foot Bertram yacht (Bertram
yacht) from Norwood Marine, Inc. (Norwood Marine). Petitioners
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