Robert R. Plante and Mary B. Plante - Page 4

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          president of BCBI, and the corporate resolutions were signed by             
          petitioner as the sole member of BCBI's board of directors.  The            
          funds advanced by petitioner on both occasions were used for                
          BCBI's current operating expenses.                                          
               Except for the amounts and due dates, the terms and                    
          conditions of the notes are identical.  Each refers to petitioner           
          as the lender and BCBI as the borrower.  The advances are                   
          characterized as loans from petitioner to BCBI with principal and           
          interest (prime rate plus 2 percent computed quarterly) due in              
          1 year from the date of the note.  Each note was renewable at the           
          option of petitioner (as the lender).  If BCBI defaulted on any             
          term of the notes, became insolvent, filed a bankruptcy petition,           
          or had a receiver appointed, the notes would become immediately             
          due and payable in full.  Neither note was fully paid as of its             
          due date.  The notes were not renewed, and the repayment periods            
          were not extended.                                                          
               Petitioners reported interest income from BCBI on their                
          joint Federal income tax returns as follows:                                
                              Year            Amount                                  
                              1987           -0-                                      
                              1988           -0-                                      
                              1989           $39,102                                  
                              1990           35,236                                   
                              1991           20,599                                   

          Although less than clear from the record, it appears that from              
          time to time prior to December 20, 1991, petitioner, or                     

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