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under a combination of the specific item and bank deposits
methods of proof.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
When the petition was filed, petitioner resided in Salt Lake
City, Utah.
During the years in issue, funds were transferred to
petitioner from relatives, friends, and others (hereinafter
jointly referred to as investors), and petitioner used the funds
to make numerous investments in publicly traded stock.
For each year in issue, the identity of most investors who
transferred funds to petitioner, the total amount of funds
transferred to petitioner, and the nature and purpose of funds
transferred to petitioner are not established in the record.
During 1984 through 1989, after receipt of funds from
investors, petitioner generally did not treat the funds received
from investors as the funds of the investors. Rather, petitioner
deposited the funds received from investors into his personal
bank accounts, and petitioner used the funds to enter into
numerous transactions for the purchase and sale of stock and
commodities on his own behalf.
With funds received from investors, petitioner also
participated in promotional and market manipulation of the stock
of a number of corporations, including Cellwest, Inc. (Cellwest),
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