Sam F. and Ingrid D. Ford - Page 6

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          Brokerage Accounts       Total     Tillex       BVD      Other              
          Black Bird - 1986   $2,443,127   $1,826,439     $599,115    $17,573         
          Toronado   - 1986   1,376,606    1,081,071      235,142     60,393          
          Canadian American - 1986 351,888   87,678      267,654     (3,444)          
          "       "     - 1985     130,690   52,640       12,705     65,345           
          Solar Aqua - 1986        384,262   60,726      305,704     17,832           
          "   "   - 1985           48,759    38,199       10,560     --               
          Bear & Pebble - 1986     24,751    24,751    –     --                       
          For Door - 1986          219,441   200,030   2,480     16,931               
          "   "   - 1985           184,975   160,665       20,935      3,375          
          Pooh-Bear - 1986         284,408   267,930   –        16,478                
          "    "  - 1985         154,827      151,424        –         3,403          
                              5,603,734    3,951,553    1,454,295    197,886          
               Following the Fatico hearing, the U.S. Attorney for the                
          Southern District of New York, in a letter dated May 21, 1992,              
          advised respondent's Regional Counsel that                                  
               On May 13, 1992 the court sentenced Mr. Ford to five                   
               years of imprisonment, three additional years of                       
               imprisonment suspended and five years probation.                       
                    Pursuant to IRC �7602(c)(2)(B), the above action                  
               constitutes a termination of the referral, and as such,                
               you are now free to seek appropriate civil action.                     
                    You are reminded that rule 6(e) of the Federal                    
               Rules of Criminal Procedure greatly restricts the civil                
               use of items constituting matters occurring before the                 
               Grand Jury.                                                            
               Eight days later, Regional Counsel's office advised the                
          District Director of Internal Revenue that it had closed                    
          petitioner's criminal matter.  It advised that the matter "is               
          released for civil consideration."  It continued:                           
                    You are reminded that no civil use of any grand                   
               jury material may be made without a rule 6(e) order,                   
               unless such material was made public through trial or                  
               otherwise.  Additionally, the situations wherein a rule                
               6(e) order can be obtained are greatly limited.                        
               Therefore all information subject to the secrecy                       
               requirements of rule 6(e) derived directly or                          
               indirectly through the grand jury process, inclusive of                
               exhibits, descriptive statements in reports and all                    




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