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totaling $135,869 to the IRS to pay his personal tax liabilities;
(3) issue check Nos. 453 and 457 to himself in the total amount
of $200,000; and (4) wire transfer $1 million to First American
Title Guaranty Co. for the purpose of funding a $2,213,000
secured promissory note with respect to which Burton and
Elizabeth held a 45.188-percent interest as joint tenants.
In 1995, Burton caused NPI to issue: (1) Check No. 469 for
$23,331 payable to the IRS to pay his personal tax liabilities;
(2) check Nos. 474, 475, 486 in the aggregate amount of $400,000
to himself and/or his wife; (3) check No. 477 for $1 million
payable to Jack White & Co. to establish an investment account in
the name “Burton O. Benson”; (4) check No. 478 for $1 million
payable to USAA Mutual Fund to establish an investment account in
the Bensons’ names; (5) check Nos. 482 and 485 in the respective
amounts of $5,441.55 and $4,860.81 payable to Insight Capital
Research & Management, Inc., to establish an investment account;
and (6) check Nos. 487, 488, and 489 for $100,000 each to Eric,
Brad, and Mark.
5. Baden Spiel Haus Partnership
During the years 1989, 1990, 1993, and 1994, Burton was a
partner owning a 25-percent interest in the Baden Spiel Haus
partnership. Baden Spiel Haus owned and operated a ski cabin in
California. The Bensons claimed partner deductions of $1,281,
$1,182, $1,473, and $2,635, for 1989, 1990, 1993, and 1994,
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