Jerry S. Payne - Page 15

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          significant payments to various banks.  The payments apparently             
          related to various personal and business obligations that petitioner        
          owed to the banks, such as petitioner’s guaranty of the $705,000            
          TexCommBk loan.  Petitioner's books and records, however, and the           
          evidence herein, generally fail to establish either the specific            
          nature of the payments (whether principal or interest) and/or the           
          specific nature of the related debt obligations (whether personal or        
          business).  The schedule below summarizes the payments that                 
          petitioner made to the various banks and, where established in the          
          record, indicates the general nature of the payments:                       

          Bank             Nature of Payments        1987             1988            
          TexGuarantyBk                           $119,146         $ 58,702           
          TexCommBk Guarantor $705,000 Debt       76,361           19,139             
          TexCommBk                               16,763           11,669             
          TexAmBkSW                               7,254           10,361              
          Merabank       Mortgage on Residence    19,402           30,666             
          Savings Banc                            3,658            4,482              
          Other Banks                               27,069              250           
                                  Total          $269,653       $135,269             

               Forms 1099-INT that respondent received relating to petitioner         
          for 1987 and 1988 indicate that petitioner paid the following               
          interest expenses:                                                          

                                          Interest Paid                               
                    Bank                  1987          1988                          
                    Merabank            $15,965        $27,397                        
                    TexGuarantyBk         9,204         12,251                        
                    TexCommBk           13,526         20,336                         
                    TexAmBkSW           7,254            --                           
                    Savings Banc          2,079            --                         
                                                                                     
          Total                         $48,028        $59,984                        






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