Donald R. Martin - Page 6

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                    for petitioner's personal loan to Jackson.  These notes were to                                                                                        
                    be completed by petitioner or Activewear if Jackson or his                                                                                             
                    corporations did not repay the loans.                                                                                                                  
                              Petitioner recorded all of the loans in Activewear's books.                                                                                  
                    Petitioner wrote a check for every loan and completed the check                                                                                        
                    stub in the Activewear checkbook.  Activewear made short-term                                                                                          
                    loans to Jackson until May 1991.                                                                                                                       
                              3.        Jackson's Repayment History                                                                                                        
                              Jackson timely repaid all of the Activewear loans for 2�                                                                                     
                    years until about August 1990.  At that time, his repayments                                                                                           
                    began to be late and some of his checks bounced.                                                                                                       
                              In 1990, Activewear lent $2,070,900 to Jackson's                                                                                             
                    corporations and Jackson's corporations repaid $1,752,900.                                                                                             
                    Activewear continued to lend money to Jackson because petitioner                                                                                       
                    believed that Jackson would be able to repay the loans if he                                                                                           
                    could continue to operate.  In 1991, petitioner lent $958,880 to                                                                                       
                    Jackson's corporations and Jackson's corporations repaid                                                                                               
                    $832,786.06.  Jackson's outstanding loan balances were $318,000                                                                                        
                    for 1990 and $126,094 for 1991.                                                                                                                        













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