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renewal, renegotiation, modification, or extension of the
1986 loans. Second, there is no other evidence that the
parties to the loan intended to modify their contractual
relationship in any manner. In fact, we are unable to find
from petitioner's vague and evasive testimony that he was
even aware of the quarterly repayment requirements in the
notes. Petitioner testified on direct examination as
follows:
Q Dr. Garcia, the stipulated notes call
for quarterly repayments. In fact, were
those quarterly repayments ever made?
A No.
Q What was your understanding with regard to
the repayment of the notes?
A Well, according to the advice given to
me by my CPA was that payment would be set
up and that was the advice that I got. To
me that plan was never the note.
Q Did your CPA, Mr. Glen, ever tell you when
the notes should be repaid?
A No, sir.
* * * * * * *
Q * * * What was your understanding with
regard to those quarterly payments?
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