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During some portion of the years in issue, petitioners
maintained the following CD accounts at Sunbelt Savings:
Account Name Account No.
Dennis Gandy 1-03-00006962
Dennis Gandy 1-03-00006970
Dennis Gandy 1-03-00007002
Dennis Gandy, Trustee for Carolyn or Dominick Gandy1-03-00006988
Dennis Gandy, Trustee for Carolyn or Dominick Gandy1-03-00007218
The first four CD’s listed above were funded with the
proceeds from the SBA loans. Petitioners deposited a few
mortgage payments into account No. 1-03-00007218, along with the
interest from the other four CD’s. Petitioners transferred funds
from this CD account to the nursery bank account as follows:
Date Amount
July 25, 1985 $45,000.00
Nov. 25, 1985 20,000.00
July 8, 1986 20,000.00
Oct. 1, 1986 23,158.12
Petitioners closed all five CD accounts at Sunbelt Savings on
April 16, 1987. The proceeds were used to reduce the balance of
the PCA loans and to pay off the December 18, 1986, loan for
$90,000, and the August 1, 1986, loan for $90,000.
During some portion of the years in issue, four CD accounts
were maintained with the First National Bank of Canton styled
"Carolyn Gandy" (account Nos. 50-5668-4, 50-5669-2, 50-5827-6,
50-5847-4). The four CD’s that established those four accounts
were purchased during 1987 for a total of $10,800, $8,400 of
which was presented in cash.
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