Samuel C. Stone and Susan C. Stone - Page 5

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               By December of 1987, Stone Jessup's debt to the bank                   
          exceeded $400,000.  Notes evidencing the debt were due and had to           
          be paid or refinanced.  Because of Stone Jessup's financial                 
          situation at the time, the bank was unwilling to renew Stone                
          Jessup's loans or grant the corporation further extensions of               
          credit unless:  (1) Petitioner assumed personal liability for any           
          existing or future debt by acting as a comaker with Stone Jessup            
          on various debt instruments; (2) petitioners agreed to                      
          collateralize the debt by placing a mortgage on their residence             
          in favor of the bank; (3) certain stock owned by petitioner was             
          pledged to the bank; and (4) petitioner obtained, at his expense,           
          certain minimum levels of credit life insurance naming the bank             
          as beneficiary.  Beginning in 1988, Stone Jessup's and                      
          petitioner's credit arrangements with the bank were restructured            
          in accordance with the above terms.                                         
               On a Schedule A filed with their 1991 return, petitioners              
          claimed a miscellaneous itemized deduction in the amount of                 
          $41,906.55 for interest payments made to the bank during that               
          year on account of loans made under the above-discussed credit              
          arrangements.  Of the amount deducted, $41,496.98 was "paid" to             
          the bank by notes co-made by Stone Jessup and petitioner (the               
          relevant notes were signed by petitioner, individually, and in              
          his capacity as president of Stone Jessup), and $409.57 was paid            
          directly to the bank on petitioner's behalf as a gift from                  
          petitioner's father, who was a director of the bank.  In                    




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