Woody F. Lemons - Page 24

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             in consideration of his cooperation with the Government                  
             in connection with its investigations of other savings and               
             loan associations.                                                       
                  In December 1990, Mr. Dixon was convicted on 23 counts              
             of bank fraud and was sentenced to serve a term of 5 years               
             in prison.  In July of 1992, Mr. Dixon entered into a plea               
             bargain with respect to eight other counts of bank fraud                 
             for which he had been indicted.  He was sentenced to serve               
             another term of 5 years in prison, with the second term to               
             run consecutively with the first.  Mr. Dixon ultimately                  
             served 44 months in prison.  As part of his 1992 plea                    
             bargain, Mr. Dixon cooperated with the Government in its                 
             investigations of other savings and loan associations.                   
             Mr. Dixon testified in two trials about criminal activities              
             at Vernon.                                                               
                  The separate 1986 income tax returns filed by                       
             petitioners include identical Schedules C, Profit or (Loss)              
             From Business or Profession, for a business described as                 
             "Time-Share Unit Sales".  Each petitioner reported one-half              
             of the amount realized from the sale of a club membership                
             to Mr. Anderson, $77,500, as "Gross receipts or sales" from              
             that business.  Each petitioner also reported the same                   
             amount, $77,500, as "Cost of goods sold" and accordingly,                
             reported no gross profit from that business.                             






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