Ella Freidus - Page 11




                                        - 11 -                                         

               Ivory Land also maintained an account at Chase.  Its net                
          deposits were as follows: $1,343,034, $647,998, $515,319 and                 
          $1,805,311 for the taxable years 1987, 1988, 1989, and 1990,                 
          respectively.  Petitioner drew checks upon this account in the               
          following amounts: $80,875, $59,005, $52,116, and $59,850,                   
          respectively.                                                                
               Petitioner maintained an account at Chase in her name during            
          the years in issue.  Net deposits into this account were as                  
          follows: $138,698, $90,649, $21,419, and $150 for the taxable                
          years 1987, 1988, 1989, and 1990, respectively.  At least $20,000            
          of transfers into petitioner's account is directly traceable to              
          transfers from Ivory Land and Ivory Ranch.  Petitioner's account             
          also received transfers of proceeds from petitioner's leases and             
          horse-related activities in the following amounts: $88,092,                  
          $31,015, $8,122, and $8,700 for the taxable years 1987, 1988,                
          1989, and 1990, respectively.                                                
               Petitioner fully authorized Mr. Freidus to act as her agent             
          during the years in issue.  Mr. Freidus, from time to time,                  
          requested that petitioner give him blank corporate checks affixed            
          with petitioner's signature.  Petitioner regularly acceded to his            
          requests.  Petitioner was aware of the expenditures and                      
          investments, which included investments in real estate and                   
          horses, which Mr. Freidus made on her behalf.  Petitioner knew               
          what checks were being written and what they were used for.                  





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