Ramon and Irma Ortiz - Page 6

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          Alvarado Transactions                                                       
               Angel Luis Alvarado (Mr. Alvarado) sent Mr. Ortiz a $14,100            
          check in 1991 and a $13,000 check in 1992, both drawn on the                
          account of Asomante Auto Sales, a company in Puerto Rico that was           
          a customer of R&X Auto Sales.  When submitted to the bank, the              
          checks were marked with notations about advances for automobiles.           
          After the checks were processed through Banco Popular in Puerto             
          Rico and returned to Mr. Alvarado, the notations on the checks              
          were changed by Mr. Alvarado to read "prestamo", the Spanish word           
          for loan.  Mr. Ortiz repaid Mr. Alvarado by sending him used                
          cars.  He retained part of the advances as his "commission".  No            
          documents were executed to formalize these advances.  No interest           
          was paid by Mr. Ortiz on the advances.                                      
          Loan From Luna                                                              
               On May 10, 1991, Mr. Ortiz received a $20,000 bank check as            
          a loan from Anibal Rivera Luna (Mr. Luna), who is related to Mrs.           
          Ortiz.  On May 15, 1991, petitioners purchased four lots in                 
          Marydia, Florida, as investment property.  Petitioners paid                 
          $29,767.24 at the closing.  Petitioners did not deposit an amount           
          of $20,000 into their personal bank account or the business bank            
          account in May 1991.  Petitioners did not withdraw the amount of            
          $29,767.24 from either account in May 1991.                                 
          Income Tax Returns                                                          
               Mr. Ortiz provided his accountant and return preparer, Paul            
          Solano (Mr. Solano), with information and data pertaining to R&X            




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