Edward E. and Constance M. Thorpe - Page 9

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          policies on each of the individuals.  On July 1, 1983, Mr. Thorpe           
          executed an application for disability insurance with Time                  
          Insurance Co. as the insurer.  On November 4, 1989, Mr. Echols              
          executed an application, as owner, for disability insurance with            
          Time Insurance Co.  ETCO paid the insurance premiums on both                
          disability insurance policies and, subsequently, deducted the               
          expenses on its tax returns for the years in issue.  ETCO also              
          maintained liability, workman's compensation, commercial auto,              
          medical, excess liability, and casualty and surety insurance.               
               In 1988, Mr. and Mrs. Thorpe signed two vehicle lease                  
          agreements on behalf of ETCO for two vehicles they drove during             
          the years in issue.  ETCO made the lease payments for both of the           
          automobiles during the years in issue.  Both lease agreements               
          listed Mr. and Mrs. Thorpe as the lessees of the automobiles, and           
          both automobiles were leased from the same company.  The first              
          lease was for a 1988 Lincoln Towncar and was dated May 10, 1988.            
          Paragraph 24 of the lease agreement on the Lincoln contained two            
          boxes in which the lessees could indicate that the automobile was           
          intended to be used for either business purposes or personal use.           
          Neither box was marked to indicate that the lessees intended to             
          use the Lincoln for either business or personal use.  The second            
          lease was for a 1988 Mercury Colony Park and was signed July 20,            
          1988.  Paragraph 24 of the lease agreement for the Mercury                  
          specifically designated the vehicle's use as being for business.            






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