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With the exception of one check to the nursery in the amount of
$7,667.99 that was paid on September 14, 1987, nearly all of the
funds paid from this account went for the insurance premiums or
bank charges. Previously, both insurance companies were paid
from the nursery bank account. During 1986, petitioners
deposited a total of $13,000 from the nursery bank account into
this account. During 1987, petitioners transferred another
$13,000 from the nursery bank account and, during February 1987,
deposited a small amount of nursery receipts into this account.
Account No. 12-6064-5 at First National Bank of Canton was
used primarily for petitioners' mortgage lending activity. All
11 deposits made during 1986 were in cash, with the largest being
$9,000; the 1986 deposits totaled $42,796.91 and began on
July 28, 1986. All deposits from January through August 1987
were in cash; there were 11 such deposits ranging in amounts from
$1,990 to $7,476.34. Deposits occurring later in 1987 also
included mortgage payment checks from the borrowers. Deposits
during 1987 totaled $104,760.34. All identifiable checks that
were written on this account during 1986 and 1987 were payable to
mortgage borrowers, with the exception of one check for $1,000
that was payable to Mrs. Gandy during 1986 and one check for
$10,000 to the nursery in 1987.
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