Albert Lemishow - Page 3

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               On December 13, 1993, petitioner completed a subscription              
          agreement to purchase 30,000 shares of GP Financial Corp. stock             
          at $15 a share for a total purchase price of $450,000.  The Green           
          Point Savings Bank (Green Point) was responsible for taking the             
          stock orders and payments for the subscription offering.                    
               As of December 1993, petitioner maintained Keogh accounts              
          and IRA's with Green Point and Apple Bank for Savings (Apple).              
          On December 14, 1993, petitioner's account balances in the Keogh            
          accounts and IRA's at Green Point totaled $327,252 and those at             
          Apple totaled $165,695.  On December 14, 1993, petitioner made              
          the following withdrawals from his Keogh and IRA accounts                   
          (amounts rounded down to the nearest whole dollar):                         
                                                       Type of                        
                    Bank                Amount         Account                        
                    Green Point         $250,651       Keogh                          
                    Green Point         50,130         Keogh                          
                    Green Point         13,939         IRA                            
                    Apple               153,828        Keogh                          
                    Apple               6,377          IRA                            
                    Apple               5,489          IRA                            
                    Total               $480,414                                      
          Green Point and Apple withheld Federal income tax from the                  
          distributions of $50,130.00 and $153,828.00, respectively, in the           
          amounts of $12,532.58 and $30,765.62, respectively.                         
               Petitioner used the net Keogh and IRA distributions                    
          ($437,117) plus $12,883 of his own funds to pay the $450,000                
          purchase price of the GP Financial Corp. stock.  On January 28,             





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