Woody F. Lemons - Page 51

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                  A    Yes.  I believe the venture loaned us some                     
                       money to make the payments.                                    
                  Q    So you are saying the venture loaned you                       
                       the money to put the down payment and also                     
                       loaned you the money to make the payments                      
                       on the dues.  Is that correct?                                 
                  A    That is my recollection.                                       
                  Q    And did you ever pay any of that money back                    
                       to the joint venture?                                          
                  A    No.                                                            

             The record of these cases contains no documentary evidence               
             of indebtedness of the joint venture to Mr. Dixon or to                  
             petitioner for the payment of annual dues.                               
                  During his testimony at trial, petitioner could not                 
             say for certain whether he had paid the annual dues from                 
             his own funds or whether he had received that amount from                
             the joint venture.  Petitioner's testimony on this issue                 
             is as follows:                                                           

                  Q    Did you pay those dues with your own                           
                       money or did you borrow that from the                          
                       venture?                                                       
                  A    I thought I paid with my own money.                            
                       I heard Mr. Dixon testify that he                              
                       borrowed it from the venture, and I                            
                       would assume if he did, I did.  But                            
                       I don't remember it that way.  I can't                         
                       swear either way.  I don't think we                            
                       borrowed it from the venture.                                  








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