Dennis C. Gandy - Page 29

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          $20,501 in cash for the purchase of real estate, causing a                  
          Currency Transaction Report to be filed by Mineola Federal                  
          Savings and Loan Association.  On December 23, 1986, petitioners            
          purchased a mink coat for $2,097.24; they paid $1,900 of this               
          amount in cash and charged the balance to their American Express            
          card.                                                                       
          Petitioners' Divorce                                                        
               Petitioners were experiencing marital difficulties during              
          the mid-1980's.  Petitioners entered into a divorce agreement on            
          June 13, 1988.  This agreement was incorporated in the final                
          decree of divorce signed on June 14, 1988.  The agreement awarded           
          the following property to Mrs. Gandy:  the loan notes that were             
          held by petitioners (said to total approximately $869,000);                 
          $50,000 to be paid on the date of divorce; $50,000 per year for             
          5 years to be paid annually commencing on June 15, 1989; a 1985             
          Cadillac convertible; a 1986 Chevrolet van; the travel agency;              
          40 percent of net recovery from a pending lawsuit; and all                  
          personal property items in her possession.  The property awarded            
          to Mr. Gandy was:  the nursery, the marital home, 60 percent of             
          the net recovery from the pending lawsuit, and all personal                 
          property items in his possession.  Among the liabilities that               
          were assumed by Mrs. Gandy were any debts of the travel agency              
          and 40 percent of the tax liabilities for 1987 and prior years.             
          Liabilities assumed by Mr. Gandy included those of the nursery              





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