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Dogwood Acres, and Saudi Corp. He also stated that the
transaction was originally a joint venture between Saudi Corp.
and Dogwood Acres; however, on the advice of his certified public
accountants, with whom he had done business for more than 25
years, that he and Dogwood Acres could become joint venturers
with no adverse tax consequences, he included himself with
Dogwood Acres in the transaction because he needed money for
living expenses. Petitioner's affidavit states that Dogwood
Acres was a joint venturer in the transaction but does not
explain why Dogwood Acres was entitled to the $250,000
commission.
Petitioner's affidavit is vague and uncorroborated.
Petitioner's affidavit did not identify the Holiday Isle
transaction by name; he referred to it as "the property which was
the subject of the William D. Barrow/Dogwood Acres, Inc, joint
venture with Saudi Corporation". Petitioner's claim that Dogwood
Acres participated in the Holiday Isle transaction is not
credible because neither petitioner nor Harris told Yost about
any involvement by petitioner or Dogwood Acres in the
transaction. We do not give much weight to petitioner's
affidavit because we find it incredible and it is unsupported by
the record, and because petitioner was convicted in 1990 of
violating 18 U.S.C. sections 2 and 1956(a)(3)(B) and (C)
(laundering drug money), and 31 U.S.C. sections 5322(a) and
5324(3) (structuring a money transaction to avoid a cash
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