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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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