Alexander M. Moye and Judy H. Moye - Page 5

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                                                                     NOTICE TO REJECT                                                                                      
                              I Alexander Moye, Jr., certify that I am an officer of                                                                                       
                              Rosewood Kennels and Southern Police Dog Academy, Inc.                                                                                       
                              and hereby elect to reject the provisions of the                                                                                             
                              Georgia Workers' Compensation Law.                                                                                                           
                    Mr. Moye signed the form on November 28, 1989.                                                                                                         
                              On November 27, 1989, Commercial Union Insurance Co.                                                                                         
                    prepared and issued a workers' compensation and employers'                                                                                             
                    liability policy to "Rosewood Kennels and Southern Police Dog                                                                                          
                    Academy Inc." for October 31, 1989, to October 31, 1990.  The                                                                                          
                    policy included JAM Bonding's Federal identification number as                                                                                         
                    though it belonged to Rosewood Kennels.                                                                                                                
                              3.        Buying Land for the Business                                                                                                       
                              In November 1989, petitioners told Oddo that they were in                                                                                    
                    the process of establishing their police dog training business.                                                                                        
                              On December 7, 1989, petitioners bought 140.9 acres in Pike                                                                                  
                    County, Georgia.  The land was titled in their individual names.                                                                                       
                    Petitioners used 26 of the 140 acres for their police dog                                                                                              
                    training business.                                                                                                                                     
                    D.        SBA Loan                                                                                                                                     
                              1.        Initial SBA Loan Application                                                                                                       
                              On December 8, 1989, petitioners applied to the U.S. Small                                                                                   
                    Business Administration (SBA) for a $550,000 loan guaranty.                                                                                            
                    Thomas L. Redding, the controller of the United Bank Corp. of                                                                                          
                    Barnesville, Georgia (United Bank), prepared the application.                                                                                          
                    Part of the application said:  "If Applicant is a proprietor or                                                                                        

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