Leo and Alla Goldberg - Page 22

                                        -22-                                          
          The purpose of these checks is unclear from the record.                     
          Petitioners did not report any of the above amounts on their 1991           
          Schedule C.                                                                 
               During 1990 and 1991, petitioners paid the following amounts           
          to the Chornys:                                                             
          Date         Payee        Amount             Memo                           
          01/19/90  Vladimir Chorny$ 2,025   5,000 for stock @ 18� per share          
          01/19/90  Vladimir Chorny5,000     None                                     
          06/24/91  Margarita Chorny  30,000 Lisa Shumin loan 1 year                  
          09/20/91  Vladimir Chorny9,000     None                                     
          15 Hastings                                                                 
               On November 10, 1986, petitioners acquired Lots 20 and 22 in           
          Block 212 of Huntington Beach, California (13th Street), for                
          $225,000.  On October 30, 1989, petitioners opened escrow on                
          their purchase of 15 Hastings, Laguna Niguel, California                    
          (15 Hastings), for $610,000.  Petitioners considered 15 Hastings            
          to be the property that replaced the 13th Street property.                  
               On or about November 15, 1989, petitioners obtained a                  
          $390,000 loan from World Savings and Loan Association (World                
          Savings) and used the proceeds from this loan to acquire                    
          15 Hastings.  The World Savings loan was secured by a first trust           
          deed on 15 Hastings.  On November 20, 1989, escrow closed for               
          petitioners' acquisition of 15 Hastings.                                    
               On November 1, 1989, petitioners and the Woods executed a              
          four-page document entitled "Lease Option" for 15 Hastings.  The            
          Woods were in the midst of a divorce, and Catherine Wood                    
          (Mrs. Wood) needed a place to live.  At this same time, the Woods           
          were trying to sell their marital residence.  The Lease Option              


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