Albert M. Graham and Martha A. Graham - Page 15

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          account; instead, these amounts were deposited in O’Leary’s money           
          market account at Merrill Lynch in 1998.                                    
               In 1998, Sieveke collected $100,000 in disputed legal fees             
          from Arnett and deposited it in his attorney-client trust                   
          account.  Petitioner told Sieveke to pay the $100,000 to O’Leary.           
          Around March 13, 1998, petitioner delivered Sieveke’s $100,000              
          check, which contained the notation “Al Graham loan repayment”,             
          to O'Leary.  O’Leary had not lent $100,000 to petitioner,                   
          however.  O’Leary deposited the $100,000 in his money market                
          account at Merrill Lynch on March 17, 1998.  Several days later,            
          petitioner told O’Leary to write a $42,500 check to Edgar and a             
          $3,500 check to petitioner’s interior decorator.                            
               Chen paid legal fees of $22,000 to petitioner.  Petitioner             
          sent Chen’s check to O'Leary, who deposited it in his Merrill               
          Lynch account around May 1, 1998.                                           
               Attorney John Gueren collected $13,421.64 in legal fees from           
          Markam for legal services rendered by petitioner.  Markam’s                 
          payment was delivered to O'Leary.  O’Leary deposited it in his              
          Merrill Lynch account on July 14, 1998.                                     
               From March to September 1998, at petitioner’s direction,               
          O’Leary wrote the following checks totaling $119,561 from his               
          Merrill Lynch account:                                                      









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