Evert E. and Eva F. Berglund - Page 4

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                  On August 24, 1976, petitioner and his spouse mortgaged all                           
            of their Illinois farmland to the Federal Land Bank of St. Louis                            
            (FLB) for the principal sum of $625,000.  The FLB mortgage is a                             
            first lien against petitioner and his spouse's Illinois farmland.                           
            On August 30, 1978, petitioner and his spouse obtained a second                             
            mortgage on all of their Illinois farmland from the Farmers Home                            
            Administration (FHA) in the principal sum of $70,000.  On May 25,                           
            1979, petitioner and his spouse obtained a third mortgage on all                            
            of their Illinois farmland from FHA in the principal sum of                                 
            $310,000.                                                                                   
                  Petitioner and his spouse's Illinois farmland was divided                             
            into seven tracts.  As of August 3, 1983, tracts 1, 2, 3, 4, 5,                             
            and 6 of petitioner and his spouse's Illinois farmland were held                            
            in fee simple title in the name of the First National Bank of                               
            Danville (FNB), as trustee under a trust agreement dated August                             
            3, 1983, known as land trust No. 5179, and tract 7 of petitioner                            
            and his spouse's Illinois farmland was held in fee simple title                             
            in the name of FNB, as trustee under a trust agreement also dated                           
            August 3, 1983, known as land trust No. 5180.  The FNB land                                 
            trusts Nos. 5179 and 5180 provided that FNB would manage the                                
            Illinois farmland owned by petitioner and his spouse.  Petitioner                           
            and his spouse were the beneficial owners of the property of the                            
            trusts.                                                                                     
                  On August 4, 1983, petitioner and his spouse and their                                
            daughter and son-in-law, Eva L. Dunavan and Joseph E. Dunavan,                              




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