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obtaining a mortgage. Petitioners' real estate agent suggested Mr.
De Ocampo's mother, Rosita De Ocampo, and father, the late
Felicismo De Ocampo, purchase the Montclair property because they
had a better credit rating than petitioners and could obtain a
mortgage on more favorable terms.
On December 2, 1989, Mr. De Ocampo's parents signed a deposit-
receipt and purchase contract for the purchase of the Montclair
property for $300,000. The contract provided that Mr. De Ocampo's
parents were purchasing the property for their own account, and
that the contract was subject to the termination of the agreement
signed by seller and petitioners on October 14, 1989.
Mr. De Ocampo's parents obtained a loan from Home Savings of
America (Home Savings) to finance the purchase of the Montclair
property. Petitioners and Mr. De Ocampo's parents agreed that
petitioners would live in the Montclair property and pay all
mortgage, insurance, property tax, and utility bills for the
residence. However, there was no written agreement to that effect,
and none of the documentation involving Home Savings, the seller,
or any other party indicated that Mr. De Ocampo's parents purchased
the Montclair property on behalf of petitioners, or that
petitioners were the owners of the property.
Loan statements and property tax bills were mailed to Mr. De
Ocampo's parents. When a bill arrived in the mail, Mr. De Ocampo's
mother would telephone petitioners, and they would stop at the
residence of Mr. De Ocampo's parents to obtain the bill. When
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