Albert J. and Helen R. Desantis - Page 16

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          general partner, to make short-term or GAP loans to the limited             
          partnerships at an interest rate of 2 percent above the prime               
          rate.  The GAP sheets purport to record that petitioner made such           
          loans and that the limited partnerships paid interest to                    
          petitioner.  The record does not reflect that the limited                   
          partnerships made payments of principal to petitioner.                      
               Petitioner caused checks to be issued from the partnerships            
          payable to himself, bearing the notation "second mortgage                   
          interest".  The second mortgage interest is attributable to                 
          second mortgage loans purportedly made by petitioner to the                 
          partnerships.  The record does not reflect the terms of any                 
          second mortgage loans.  Furthermore, there is no evidence that              
          petitioner transferred any funds to the partnerships in                     
          accordance with the purported second mortgage loans.                        
               Petitioner also caused the partnerships to pool funds to               
          purchase jumbo certificates of deposit during the years at issue.           
          A jumbo certificate of deposit is a certificate of deposit in the           
          amount of $100,000 or more.                                                 
               Petitioner owned rental properties in the Ohio State                   
          University and other Columbus, Ohio, areas.  During the years in            
          issue, petitioner owned from 31 to 79 such rental properties.               
          Petitioner hired several independent contractors (the laborers)             
          to clean and repair the rental units.  Petitioner would present             
          the laborers with their weekly paychecks which they, in turn,               





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