Bruno and Francesca Tabbi - Page 8

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          4.   Americana                                                              
               Before and during the years in issue, petitioner husband               
          transferred real estate without consideration from petitioners to           
          Americana, and from Americana to petitioners.  During the years             
          in issue, petitioner husband deposited rental and installment               
          sales income from real estate owned by Americana to the Earl Kiem           
          Bell/Shores escrow account, which petitioner husband controlled.            
               In 1987, petitioner husband transferred $9,800 to                      
          Americana's account.  Petitioner husband liquidated Americana in            
          1987.  At that time, he distributed its assets, including                   
          financial investments and real estate to himself and assumed its            
          liabilities.  In 1987, petitioners paid various expenses relating           
          to real estate owned by petitioners and/or Americana.                       
               From 1987 to 1989, petitioner husband obtained second                  
          mortgages on, and rented, real properties owned by petitioners              
          and/or Americana.  At the same time, he sold parcels of real                
          estate that were owned by petitioners and/or Americana in 1987,             
          1988, and 1989.  He sold five houses in 1987, three in 1988, and            
          two in 1989.  Also in those years, petitioner husband used funds            
          invested in Americana to buy real estate for Americana.                     
               Petitioners earned interest of $259 in 1987, $306 in 1988,             
          and $379 in 1989.                                                           









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