Robert T. and Mary F. Gow - Page 12




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          was providing. Petitioners rarely, if ever, spoke with the                    
          management of these resorts.                                                  
               On a number of occasions, other members of the “WVI management           
          team” accompanied petitioners on these trips.  On at least one                
          occasion each, David Legere (president of Offsite) and Senator                
          Stanley Walker, along with their spouses, traveled with petitioners           
          and had their expenses paid by WVI.  On these trips, petitioners              
          and their associates stayed at first-class resorts and dined at the           
          finest restaurants.  During their December 1990 trip to Hawaii,               
          petitioners stayed at the Halekulani Hotel for $850 per night and             
          dined at the La Mer restaurant for meals costing $900 or more; the            
          next month they stayed at the Lodge at Koele for $900 per night and           
          dined at expensive restaurants, with one meal costing over $2,000.            
               On these trips, petitioners enjoyed room service and many of             
          the local attractions. Over the course of 4 days, petitioners                 
          incurred $462 in room service charges.  During this same period,              
          petitioners visited local tourist attractions such as Sea Life                
          Park, Ala Moana shopping center, and the Waipio Valley historical             
          site.                                                                         
               During the audit for the years in question (discussed infra),            
          Dr. Gow was requested to provide itineraries for the trips to                 
          Hawaii and Key West.  These itineraries, which purport to summarize           
          petitioners’ activities during those trips, were reconstructed by             








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