Alexander M. Moye and Judy H. Moye - Page 8

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                    Georgia issued, a name reservation certificate for "Rosewood                                                                                           
                    Kennels, Inc."  It was valid for 2 months.                                                                                                             
                              On February 28, 1990, Bischoff filed articles of                                                                                             
                    incorporation for Rosewood Kennels, Inc., with the secretary of                                                                                        
                    state of Georgia.  In April 1990, Bischoff billed petitioners                                                                                          
                    $100 for filing the articles of incorporation.  Petitioners paid                                                                                       
                    that bill with a check drawn on their personal checking account.                                                                                       
                    F.        Events After Petitioners Filed the SBA Loan Application                                                                                      
                              1.        Interim Construction Loan                                                                                                          
                              United Bank provided interim construction financing for the                                                                                  
                    police dog training business.  Petitioners each signed a                                                                                               
                    promissory note on March 2, 1990, for an interim loan to build                                                                                         
                    buildings and roads for the police dog training business.  That                                                                                        
                    loan provided financing until the loan guaranteed by the SBA                                                                                           
                    closed.  Petitioners used that construction loan and a loan from                                                                                       
                    Home South Mortgage to buy assets for the business.                                                                                                    
                              2.        Premium Finance Agreement                                                                                                          
                              On May 1, 1990, Mr. Moye signed a "Premium Finance                                                                                           
                    Agreement", which is a Federal truth-in-lending agreement.                                                                                             
                    Snellings Walters Insurance Agency prepared the document.  The                                                                                         
                    document states the total amount of premiums and payments, the                                                                                         
                    downpayment, the amount financed, the finance charge, the annual                                                                                       
                    percentage rate, and the payment schedule.  The document listed                                                                                        

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