Allie Ray McCullen and Shurley G. McCullen - Page 8

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          to make business contacts and to provide funds for the bank                 
          investors' needs.  Petitioner borrowed $100,000 from South                  
          Carolina National Bank to buy New-East Bank stock around 1987.              
          On their income tax returns for 1990 and 1991, petitioners                  
          deducted the interest on that loan as a business expense.                   
          Petitioner borrowed money from New-East Bank to pay farm                    
          expenses.                                                                   
               Petitioner sold his New-East Bank stock for a loss of                  
          $30,000 to $40,000 in 1994 or 1995.                                         
          E.   Loans From Other Banks                                                 
               In 1990 and 1991, petitioner paid interest on many loans.              
          The loans on which interest was paid, the deductibility of which            
          remains in issue after concessions, are listed in par. A-1 of the           
          opinion.                                                                    
               Petitioner used one of the two First American Bank loans in            
          dispute to buy the Bass Town tract.  He used the other First                
          American Bank loan as a second mortgage on his satellite office             
          in Onslow County.                                                           
          F.   Petitioners' Finances and Bank Accounts                                
               Mrs. McCullen had a personal checking bank account into                
          which she deposited her salary.  Petitioner had a separate                  
          personal bank account.  He also had two farm bank accounts and              
          one account for his real estate business.  His corporation had              
          one account.  Petitioner used money from whichever account had              
          enough money to pay other business expenses.  For example, he               




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