Michael Correra - Page 3

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            Pursuant to the March 5, 1990 agreement, petitioner increased his                            
            indebtedness on the $2,000,000 note by borrowing an additional                               
            $600,000 from Capitol Bank.  The $600,000 was stated to be for                               
            specified purposes in specified amounts, particularly, to pay                                
            interest owed on the $2,000,000 note, reduce the personal                                    
            indebtedness of Banker and Lewis to Capitol Bank (for which he                               
            was apparently responsible), and pay outstanding real estate                                 
            taxes on the Exeter Street property.  In connection with this                                
            refinancing, petitioner executed a quitclaim deed on March 5,                                
            1990, to an escrow agent.                                                                    
                  Capitol Bank was seized by the FDIC sometime prior to April                            
            11, 1991.  On April 11, 1991, due to petitioner's default on the                             
            Capitol Bank notes, the FDIC took possession of the quitclaim                                
            deed from the escrow agent.  On November 12, 1991, the FDIC                                  
            executed a Mortgage Discharge in connection with the Exeter                                  
            Street property which was recorded on December 17, 1991.  At the                             
            time the FDIC took the quitclaim deed from the escrow agent,                                 
            petitioner owed Capitol Bank a total of $3,600,000 in connection                             
            with the property.  These debts were forgiven by the FDIC's                                  
            Mortgage Discharge.                                                                          
                  During 1991, petitioner had a $3,152,867 basis in the Exeter                           
            Street property.   The parties have stipulated that if the Court                             
            determines that petitioner did not sustain a capital loss in                                 







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