Dennis C. Gandy - Page 20

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               During some portion of the years in issue, petitioners                 
          maintained the following personal bank accounts:                            
               Account Name                                 Account No.               
          Sunbelt Savings                                                             
               Carolyn Gandy                                03-1006594                
               Carolyn Gandy, Trust for Vernon Sexton, Jr.  03-10012208               
          First State Bank of Van                                                     
               The Carolyn Gandy Irrevocable Trust,                                   
                    Dennis Gandy, Trustee                   01-0892-8                 
              Dennis or Carolyn Gandy                      10-5933-6                 
          First National Bank of Canton                                               
               Dennis or Carolyn Gandy                      12-6064-5                 
               Carolyn Gandy                                12-6133-8                 
               Mrs. Gandy used account No. 03-1006594 at Sunbelt Savings as           
          a personal checking account for the Gandy family until early                
          September 1987.  She deposited checks that were written to                  
          herself from the nursery bank account into this account.                    
          Mrs. Gandy opened account No. 12-6133-8 at First National Bank of           
          Canton in September 1987.  This latter account was used primarily           
          to pay for personal expenses.                                               
               Account No. 01-0892-8 at First State Bank of Van was opened            
          with a deposit of a check for $19,500 payable to Mrs. Gandy from            
          the nursery bank account.  The funds in this account were used to           
          make a payment in the amount of $19,308.20 to Executive Life                
          Insurance Co. on September 11, 1987.                                        
               The funds of account No. 10-5933-6 at First State Bank of              
          Van were used to pay monthly drafts for life insurance premiums.            

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