James E. Griffin and Katrina F. Griffin, Transferees - Page 5

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          sentenced to prison for a term of 30 months to run concurrently             
          with the sentence imposed by the State of Florida.                          
               Mr. Fisher did not report the diverted proceeds on his                 
          Federal income tax returns for 1991 and 1992.  Using a bank                 
          deposit analysis, respondent determined that Mr. Fisher failed to           
          report income from his illegal activities of $174,789 and                   
          $118,401 for 1991 and 1992, respectively.  As previously                    
          indicated, petitioners do not contest respondent's determination            
          of deficiencies and additions to tax against Mr. Fisher.                    

          Transfers of Real Property and Mortgage Payments                            

               Mr. Fisher started planning the diversion of the telephone             
          commissions prior to June 1991.  On June 6, 1991, Mr. Fisher                
          transferred to petitioners, by warranty deed, his interest in               
          three contiguous parcels of land located at 6913 Apalachee                  
          Parkway, Tallahassee, Florida.  These parcels consisted of a 2-             
          acre parcel (parcel 1), a 0.92-acre parcel (parcel 2), and a                
          0.25-acre parcel (parcel 3).  On the date of these transfers,               
          there was only one improvement built on these parcels, which                
          consisted of a house constructed in 1989 on parcel 1.  Mr. Fisher           
          applied for the construction permit for this house, and upon its            
          completion he moved into the house and continued to reside                  
          therein until his imprisonment in 1993.  The fair market value of           

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