Joan Walters, f.k.a. Joan Gherman, and Henry Gherman - Page 11

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          dollar contributions made by FIP's professional employees to                
          qualified U.S. charitable organizations.                                    
               FIP paid the personal expenses of Mr. Gherman, Ms. Walters,            
          and other Gherman family members.  FIP paid for the cars driven             
          by petitioners and their children during the years in issue.  The           
          cars included Cadillacs, a BMW, a Town Car (Ms. Walters), and a             
          Buick (Mr. Gherman).                                                        
               FIP's books and records reflect that, dating back to 1975,             
          FIP made personal loans to FIP's clients, employees, and                    
          shareholders, including Gherman family members or entities in               
          which they held interests.  The records also reflect payments of            
          interest and principal on those loans.  Ms. Walters was not aware           
          that FIP's books recorded loans' being made to her.                         
               During the years in issue, FIP chartered a 45-foot boat, the           
          Camelot, from ShariCraig, Inc. (ShariCraig), an S corporation               
          owned by Ms. Walters until 1986 when she sold her shares to Shari           
          and Craig.  Neither Shari nor Craig was actively involved in the            
          day-to-day activities of ShariCraig.  ShariCraig's books and                
          records were maintained by Mike Landa (Mr. Landa), who also                 
          captained the boat.  The record does not reveal in which year the           
          Camelot was purchased by ShariCraig or the source of the funds              
          for that purchase.  The Camelot cost $150,000.  FIP paid                    
          ShariCraig $600 for each day it used the Camelot, with a                    
          guaranteed charter of at least two times a month.  It was docked            





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