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Street property to secure a note in the principal amount of
$24,855.83. The note was satisfied on January 24, 1986.
On March 29, 1985, petitioner and Mr. Moosbrugger executed a
mortgage on the Third Street property in favor of First National
Bank to secure a promissory note in the amount of $24,007.47. The
mortgagor was listed as the Mack & Moosbrugger partnership. This
mortgage was satisfied on December 31, 1987.
On December 28, 1987, the Mack & Moosbrugger partnership
executed a quitclaim deed of the Third Street property to Mr.
Moosbrugger, Mr. Ohlsen, Ms. Dvorak, and Mr. Carter as joint
tenants. The deed was recorded on January 6, 1988.
On December 31, 1987, a promissory note was executed by Mr.
Moosbrugger, Mr. Ohlsen, Ms. Dvorak, and Mr. Carter in favor of
Community National Bank in the amount of $150,000. The stated
purpose of the note was to purchase real estate, and the note was
secured by a mortgage on the Third Street property. On December
31, 1987, Mr. Moosbrugger, Mr. Ohlsen, Ms. Dvorak, and Mr. Carter
executed a mortgage on the Third Street property as joint tenants
in favor of Community National Bank to secure the December 31,
1987, promissory note. The December 31, 1987, note paid off
prior notes and satisfied the mortgages on the Third Street
property executed by the Mack & Moosbrugger partnership on August
29, 1978, and March 29, 1985, and the note executed and
guaranteed by Mr. Moosbrugger and petitioner dated March 29,
1985. A real estate settlement dated December 31, 1987, reflects
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