Nathanael Roman - Page 10

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          in monthly installments of principal and interest totaling $182.            
               On or about October 5, 1988, petitioner borrowed $5,351, the           
          same principal amount as the October 5 note, from Air Defense               
          Center Federal Credit Union (ADCFCU loan).  The ADCFCU loan bore            
          the same annual percentage interest rate as the October 5 note.             
          On October 7, 1988, petitioner borrowed $5,020, the same princi-            
          pal amount as the October 7 note, from Norwest Financial New                
          Mexico, Inc. (Norwest loan).  The Norwest loan bore the same                
          annual percentage interest rate as the October 7 note.  During              
          1989, petitioner repaid the ADCFCU loan and the Norwest loan by             
          using $9,966 that he borrowed from White Sands Federal Credit               
          Union (White Sands loan) at an annual percentage interest rate of           
          13 percent.                                                                 
                    Claimed Nonbusiness Bad Debt of Mr. McWilliams                    
               On December 15, 1987, Robert L. McWilliams (Mr. McWilliams)            
          signed a note (Mr. McWilliams' note) that stated that he was to             
          repay Nathanael Roman $4,500 at an annual percentage interest               
          rate of 12 percent in monthly installments of principal and                 
          interest totaling $275.  Mr. McWilliams did not pay any principal           
          or interest on that note.  When petitioner learned during 1989              
          that Mr. McWilliams was unable to pay certain creditors, he                 
          determined that Mr. McWilliams did not intend to pay the princi-            
          pal and interest on Mr. McWilliams' note.                                   








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