Robert R. Plante and Mary B. Plante - Page 5

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          petitioners, advanced other funds considered by them to                     
          constitute loans, to BCBI.  Some of the interest referred to in             
          the above table may relate to these other unspecified                       
          transactions, and the balance presumably relates to the notes.              
          Aside from the two notes previously described, petitioners                  
          presented no documents evidencing additional loans made by either           
          of them to BCBI.                                                            
               Uncertified financial statements prepared by BCBI's                    
          certified public accountants reflect, among other things, long-             
          term liabilities to petitioner as follows (year references are to           
          fiscal years ended October 31):                                             
                         Year           Liability                                     
                         1987           $320,000                                      
                         1988           396,750                                       
                         1989           392,409                                       
                         1990           419,069                                       
                         1991           491,243                                       
          No explanation of, or accounting for, the changes in the amount             
          of the liability from year to year has been provided.  We cannot            
          tell whether the above amounts include principal and interest.              
          Comparing the amount of liability for each year to the face                 
          amounts of the notes makes it obvious that, after October 31,               
          1987, the liabilities are not attributable exclusively to the               
          notes.  A statement included in BCBI's financial statement for              
          its fiscal year ended October 31, 1988, indicates that the                  
          liability with respect to that year relates to "unsecured notes             

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