Saffet and Ana Uslu - Page 3

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          to open a bank account in his name.  Petitioner husband and Haluk           
          opened a joint checking account (joint account) at California               
          Federal Bank.  Both petitioner husband and Haluk deposited money            
          into and wrote checks out of this joint account.                            
               Upon receiving his graduate degree from USC, petitioner                
          husband returned to work briefly in Turkey.  After working in               
          Turkey for approximately 1 year, petitioner husband returned to             
          the United States and began working in areas other than the field           
          of engineering.  Petitioner husband married Ana Uslu (petitioner            
          wife), and two children were born of their marriage.  During the            
          year at issue, petitioner husband was employed as a real estate             
          broker, and petitioner wife was employed as a registered nurse.             
          In 1989, Haluk married Aysun S. Aslancirit (Aysun), and, at the             
          time of his marriage, Haluk ceased making deposits into or                  
          writing checks out of the joint account.  Petitioners assumed               
          this account as their own.                                                  
               In 1990, petitioners' unfortunate financial situation forced           
          them to file for a Chapter 7 bankruptcy.  Shortly thereafter,               
          through petitioner husband's work as a real estate broker,                  
          petitioners located a house that they desired to purchase as a              
          residence.  The house was located at 733 East Alisal Street in              
          Covina, California (Alisal property).  Because of their                     
          bankruptcy and poor credit rating, petitioners were unable to               
          qualify for financing to purchase the Alisal property.                      

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