Paul A. Rendina and Janet Mae Rendina - Page 4

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          petitioner’s accounting clients:  William and Mary Foss (the                
          Fosses), Vito and Adella Navar (the Navars), and Frank and                  
          Benette Posa (the Posas).  The principal amounts of the loans               
          from the Fosses, Navars, and Posas were $53,000, $10,000, and               
          $5,000, respectively.  The loan checks were made to WSAI, and               
          deposited in WSAI’s checking account at National City Bank.  WSAI           
          issued promissory notes to  the lenders, providing that interest            
          would be paid at a rate of 12 percent per year.  The maturity               
          date of each of the notes was approximately 1 year after                    
          issuance.                                                                   
               On March 9, 1987, the Posas lent $5,000 to WSAI, and                   
          received notes as follows:                                                  
               Entity         Date           Amount                                   
               WSAI           2/17/87        $5,000                                   
               WSAI           3/01/88        5,000                                    
               WSAI4          3/01/89        5,000                                    
               On May 5, 1987, June 8, 1987, and June 29, 1987, the Fosses            
          lent $18,000, $10,000, and $25,000, respectively, to WSAI, and              
          received notes as follows:                                                  

               Entity         Date           Amount                                   
               WSAI           4/06/87        $28,000                                  
               WSAI           6/29/87        25,000                                   



          4In 1989, petitioner replaced the prior note with a note                    
          issued in the name of WSAI, which was by then no longer an active           
          corporation.  When the 1989 notes were typed, petitioner’s office           
          inadvertently transcribed the information from the client’s old             
          notes.                                                                      




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