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On January 6 and 7, 1985, the bid and asked prices for
registered, publicly traded Strata stock were $4.50 and $4.75,
respectively.
Mr. Davis claimed a $190,000 charitable contribution
deduction on the 1985 return for the donation of the Strata stock
to ODC. The 1985 return fully disclosed the contribution of the
Strata stock to ODC on Form 8283, Noncash Charitable
Contributions. Attached to the 1985 return also were Mr. Davis'
letter to the president of ODC (Sister Mary Andrew), Sister Mary
Andrew's acknowledgment letter, and a certificate, signed by
Sister Mary Andrew, concerning her understanding of the
application of rule 144 of the Securities Act of 1933 to the
donated stock.
Mr. Davis' Legal Expenses
1. Squirrel Bend Litigation/Mail Fraud
From 1968 through 1985, with the exception of a 10-12 month
period during 1980 and 1981, Mr. Davis resided on Squirrel Bend
Road in the City of Upper Arlington, Ohio. This area is known as
"Squirrel Bend".
In the spring of 1981, Mr. Davis constructed a waterline
along Squirrel Bend to provide fire protection for the
neighborhood. In accordance with procedures set forth by the
City of Upper Arlington for construction of the waterline, Mr.
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