Ronald H. Bradshaw and Monica I. Bradshaw - Page 6

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             into his account at Colonial Bank, the bank cleared for                  
             payment and paid four outstanding checks that petitioner                 
             had drawn on his account to the order of "Harbour View                   
             Fleet & Leasing".  The record does not describe the                      
             relationship of that entity to petitioner or the nature of               
             the payments petitioner made to it.  The following is a                  
             list of the amounts and dates of the four checks cleared                 
             from petitioner's account at Colonial Bank:                              

                       Check Amount             Date Cleared                          
                       $235,533                 8/11/89                               
                       216,149                  8/14/89                               
                       241,819                  8/14/89                               
                        192,439                 8/16/89                               
                  Total   885,940                                                     

                  The parties to this case have stipulated that Colonial              
             Bank suffered a loss during 1989 in the amount of $886,026,              
             the aggregate amount of the checks that Tarrant Bank                     
             returned due to insufficient funds, as opposed to $885,940,              
             the aggregate amount of the checks paid by Colonial Bank.                
             Similarly, petitioners admit receiving income from Colonial              
             Bank during 1989, in the amount of $886,026.  At all times               
             during 1989, petitioners were insolvent by more than                     
             $886,026.                                                                
                  When the Motion, Inc., checks were returned unpaid,                 




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