Harold T. and Christine B. Couch - Page 4

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          award.  After the audit, petitioners approached a number of local           
          lending institutions for the purpose of obtaining a line of                 
          credit on behalf of HTC.  However, on each occasion, they were              
          informed that such financing of a small, start-up company was not           
          possible.                                                                   
               In October 1984, petitioners obtained a personal line of               
          credit from Society for Savings secured by a second mortgage on             
          their residence.  They personally guaranteed the $20,000 credit             
          line to HTC contingent upon the contract being awarded to HTC.              
          In March 1985, the Army awarded a Cost Plus Fixed Fee Contract              
          ("the Contract") to HTC.  HTC began work under the Contract on              
          April 1, 1985.  On April 12, 1988, the Army terminated the                  
          Contract.                                                                   
               Between August 1984 and September 1989, petitioners made               
          loans to HTC in the total amount of $187,143.86.  During this               
          period and through March 31, 1990, HTC made principal payments on           
          its indebtedness to petitioners in the total amount of                      
          $97,757.36.  As of March 31, 1990, petitioners computed interest            
          outstanding on the unpaid loans to HTC in the amount of                     
          $62,480.31.                                                                 
               HTC sought the balance of the unpaid loans and interest from           
          the contracting officer of the Army.  The contracting officer               
          offered a settlement proposal for $6,107.47, the difference                 
          between the contract amount ($248,962) and the amount HTC had               
          previously been paid.  However, he denied their claim for                   




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