Marc S. Feldman - Page 3

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          Ms. Trevino gave petitioner cash to spend.  During 1996 and 1997,           
          Ms. Trevino was not employed outside the home.                              
               Beginning in January 1997, petitioner requested bank                   
          statements and documents from Ms. Trevino to show where his                 
          income was placed and what investments were made.  They met                 
          almost weekly for about 15 to 30 minutes to discuss their                   
          finances.  Around the same time, petitioner requested that                  
          Ms. Trevino purchase shares of stock in particular companies.               
          Subsequently, petitioner requested an accounting of which stocks            
          were purchased.  Ms. Trevino provided to petitioner a handwritten           
          ledger sheet accounting for the family’s investments.                       
          Ms. Trevino also provided handwritten ledger sheets to show                 
          petitioner the amounts held in their various bank accounts.                 
          Additionally, Ms. Trevino provided photocopied bank statements              
          from several financial institutions with varying account                    
          balances.  The bank statements were altered, reflected obvious              
          inconsistences, and had dates printed in an irregular form.                 
               In late July 1997, petitioner’s law firm was experiencing              
          financial difficulties.  At that time, petitioner was managing              
          partner of the law firm.  Petitioner engaged Sanwa Bank to                  
          provide a line of credit to the law firm, using his personal bank           
          accounts as collateral on the loan.  He collected statements from           
          the joint bank accounts to substantiate his income to Sanwa Bank.           








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