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before the District Courts, vitiates his belated objection now.
See Gavosto v. Commissioner, T.C. Memo. 1994-481. We hold that
there was no improper disclosure or use of grand jury information
by respondent.3
Issue 3. Cayman Islands Treaty Violation
Petitioner asserts that respondent improperly used
information that was obtained from the Government of the Cayman
Islands in violation of an agreement between the United States
and the United Kingdom.
Evidence concerning petitioner's bank accounts in the Cayman
Islands was obtained pursuant to the Agreement Concerning
Obtaining Evidence From Cayman Islands With Regard to Narcotics
Activities, Aug. 29, 1984, U.S.-U.K., 24 I.L.M. 1110 (as
extended). Petitioner challenges the use of this evidence by
asserting a violation of the agreement.
Petitioner's bank records in the Cayman Islands were
originally obtained for use in the criminal tax case in Florida.
In order to obtain these records under the terms of the
3We note that Fed. R. Crim. P. 6(e) orders were later
issued. Hugh G. Isley, Jr. (Isley), was originally petitioner's
attorney in these proceedings. When Isley began representing
petitioner, he had no information or records for petitioner and
was attempting to obtain any records he could. In July 1994, the
District Courts for the Southern District of Florida and the
Eastern District of Missouri issued Fed. R. Crim. P. 6(e) orders
allowing the grand jury material gathered against petitioner to
be used by both petitioner and respondent in these cases.
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