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When the Woods conveyed Martis Landing to petitioners, Bank
of America held a first deed of trust with a balance of about
$135,990 on the property.
Petitioners took title to Saddle Rock subject to a deed of
trust in favor of Hawthorne Savings and Loan Association
(Hawthorne), securing a mortgage with a balance, as of June 7,
1991, of $464,300.37. Petitioners also took title to Saddle Rock
subject to a deed of trust that secured a real estate loan with
Topa Savings Bank (Topa) with a balance of $203,610.12 on June 4,
1991. On June 21, 1991, petitioner paid $20,000 from California
Federal account number 5272 to Mission Viejo National Bank in
satisfaction of a third trust deed on Saddle Rock.
The funds for the following payments were withdrawn from one
of petitioners' joint accounts, California Federal account number
5272: (1) $80,000 for a loan to the Woods; (2) $50,000 for a
loan to the Woods; (3) $28,529 for a payment to Topa; and
(4) $20,000 for a payment to Mission Viejo National Bank.
Petitioners also paid the following amounts out of Dean Witter
account number 37733, a Coastline account: (1) $4,191.02 to
Placer County Tax Collector for delinquent property taxes on
Martis Landing; (2) $2,547.38 to Bank of America for delinquent
payments on the Martis Landing loan; and (3) $8,203.72 to Orange
County Tax Collector for delinquent property taxes on Saddle
Rock. The funds in Dean Witter account number 37733 were
transferred from California Federal account number 6250, a
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