Benjamin and Sallie Campfield - Page 17

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          owned the funds in account No. 030-1471-9 located in the Bank of            
          Screven County, which had a balance of zero on December 31, 1983,           
          $7,200.51 on December 31, 1984, $41.36 on December 31, 1985, and            
          $1,037.56 on December 31, 1986.  Petitioner contends that his               
          brother, Leroy Campfield, owned account No. 030-1471-9.                     
               On December 9, 1984, Leroy Campfield opened account No.                
          030-1471-9.  The signature card for account No. 030-1471-9 shows            
          "Campfield Farms Leroy Campfield" as the name of account.  The              
          only signature on the signature card is that of Leroy Campfield.            
          The signature card and the bank statements show the same                    
          Sylvania, Georgia, mailing address.                                         
               Leroy Campfield acted on petitioner's behalf when petitioner           
          purchased the Route 21 property.  Leroy Campfield gave Williams             
          $5,000 on petitioner's behalf and a purchase contract signed by             
          petitioner.  Leroy Campfield purchased equipment and supplies on            
          petitioner's behalf.  The invoices associated with said purchases           
          show Campfield farm as the purchaser.  We find that Leroy                   
          Campfield opened account No. 030-1471-9 on petitioner's behalf              
          and that petitioner owned the funds in account No. 030-1471-9.              
               Planter                                                                
               Respondent determined that petitioners acquired a planter              
          for $1,400 on March 5, 1985.  Petitioner stipulated that in 1985            
          he acquired a combine and a harrow for use on the Campfield farm.           
          Leroy Campfield purchased the combine and the harrow on                     






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