Alexander M. Moye and Judy H. Moye - Page 9

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                    "Alex Moye, Jr., Judy Moye & Rosewood Kennels, Inc. T/A Southern                                                                                       
                    Police Dog Academy" under "Insured and Address".                                                                                                       
                              3.        Invoices                                                                                                                           
                              In April and May 1990, Pete W. Onni (Onni), an employee of                                                                                   
                    petitioners' police dog training school, sent invoices totaling                                                                                        
                    $16,300 to police departments for equipment and 520 hours of dog                                                                                       
                    handler training.  The invoices were on letterhead for "Southern                                                                                       
                    Police Dog Academy, a division of Rosewood Kennels, Inc."  The                                                                                         
                    letterhead stated that petitioner was president, Mr. Moye was                                                                                          
                    secretary/treasurer, and Onni was director.                                                                                                            
                              4.        Petitioners' Conveyance of Land to Rosewood Kennels,                                                                               
                                        Inc.                                                                                                                               
                              On June 2, 1990, petitioners conveyed 26 acres of land by                                                                                    
                    deed to Rosewood Kennels, Inc.                                                                                                                         
                    G.        The SBA Loan Closing on June 2, 1990                                                                                                         
                              The SBA loan closed on June 2, 1990.  At the closing,                                                                                        
                    petitioner signed a document entitled "Compensation Agreement for                                                                                      
                    Services in Connection with Application and Loan from [Or in                                                                                           
                    Participation With] Small Business Administration" beneath                                                                                             
                    "Rosewood Kennels, Inc. (Applicant)" and above "Judy H. Moye,                                                                                          
                    President".  Petitioner also signed an SBA settlement statement                                                                                        
                    for Rosewood Kennels, Inc.                                                                                                                             
                              At the loan closing, petitioners each signed personal                                                                                        
                    guaranties for the $500,000 loan.  The guaranties stated that the                                                                                      






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