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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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