Maurice D. and Elinor Taylor - Page 8

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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              
               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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