Dennis C. Gandy - Page 22

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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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