also instructed Stern to make all subsequent payments

for the purchase of petitioner’s stock payable to the Church of

the New Age.

     On December 8, 1986, petitioner directed B.F. Pitman III

(Pitman) to open a bank account in the name of the Church of the

New Age.   Pitman was a member of the board of directors of a bank

in San Antonio, Texas, where the account was opened.       Pitman had

sole signature authority on the account, but thereafter Pitman

made deposits, withdrew funds, and handled mail in the name of

the Church of the New Age solely at the direction of petitioner.

     The following payments for petitioner’s stock in Kentucky

Wood were deposited into the account in the name of the450,618.30

Also on September 25, 1987, a check was issued by Kentucky Wood

to “Church of the New Age and International Telecommunications”
                               - 5 -


in payment of the corporation’s interest in Kywood.   That check

was also deposited into the account of the Church of the New Age.

     On September 25, 1987, Kentucky Wood issued a check payable

to Mrs. Dubose in the amount of $61,319.61 as payment for 2,693

shares of her stock in Kentucky Wood.   On October 29, 1987, at

petitioner’s direction, that check was deposited into a new

interest-bearing checking account in the name of