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indicated that the line of credit was for $280,698; interest at 2
percent above prime would be charged; and no monthly fixed payments
were required. (Petitioners disputed the amount of liability
($280,698) Irvington Federal claimed petitioner owed it.)
In March 1990 as part of a plea agreement with the U.S.
Attorney's Office, petitioner pled guilty to one count of
structuring cash transactions to circumvent the $10,000 cash
deposit reporting requirements. Judgment was entered in November
1990, and petitioner was sentenced to 12 months' incarceration. He
served 6 months in the Federal prison in Allenwood, Pennsylvania
(from January through June 1991), and was thereafter transferred to
a halfway house to serve the remainder of his sentence on work
release.
The plea agreement with the U.S. Attorney's Office stipulated
that the check-kiting scheme caused Irvington Federal to suffer a
loss of $170,000 to $280,000, and that Mr. Taylor agreed to make
restitution. Pursuant to the judgment entered by the U.S. District
Court for the District of Maryland, petitioner agreed to file any
delinquent Federal and State income tax returns.
Petitioners' Lifestyle
Throughout the years in issue, petitioners maintained a modest
lifestyle. They resided in the house they purchased in 1977; the
mortgage payments were approximately $400 per month. Petitioners
owned two cars, a 1983 or 1984 pickup truck and a late-1970's model
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