Allie Ray McCullen and Shurley G. McCullen - Page 3

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                                  FINDINGS OF FACT                                    
          A.   Petitioners                                                            
               Petitioners are married and lived in Clinton, Sampson                  
          County, North Carolina, when they filed their petition.                     
          Petitioners have a daughter who attended high school in 1990 and            
          1991.                                                                       
               Petitioner has lived in Sampson County all of his life.  He            
          has farmed since he was 13 years old.  He is a college graduate             
          with a degree in history.  He has been a licensed realtor since             
          1974, when he started to work in the real estate business.  In              
          1987, he became a director of a bank.  He sometimes borrowed                
          money from his great-aunt, Mary McCullen.                                   
               In 1990 and 1991, Mrs. McCullen was employed as a teacher              
          with the Clinton City Schools.  She earned $29,506 in 1990 and              
          $31,220 in 1991.                                                            
          B.   Petitioner's Real Estate Activities                                    
               1.   Petitioner's Purchase of Real Estate                              
               Petitioner bought various parcels of real estate before and            
          during 1990 and 1991.  In 1990 and 1991, petitioner owned the               
          Bass Town tract, Sadie Farm, Greenview tract, and Giddonsville              
          Packing tract.  He intended to resell the properties but did not            
          do so during the years in issue for various reasons.  He borrowed           
          money from various financial institutions to buy the properties.            
          Petitioners deducted interest related to these real estate                  






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