Srichai and Pusadee Rungrangsi - Page 4

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               In 1991, petitioners sold the minimarket (at a profit) for             
          Stanton Mexicatessen Restaurant                                             
               On January 7, 1992, petitioners purchased Stanton                      
          Mexicatessen, a restaurant located in Stanton, California, for              
          $355,000 (an apparent coincidence) from Sonia Finkelstein.  To pay          
          for the restaurant, petitioners obtained a $100,000 loan from First         
          International Bank (secured by petitioners' residence), received            
          $85,000 in seller's financing (which was to be repaid at an                 
          interest rate of 10 percent by January 7, 1995), and paid the               
          balance of the purchase price in cash, including the funds from Ms.         
          Eagatatt's home equity loan.                                                
               Petitioners maintained two business checking accounts1 for the         
          operation of Stanton Mexicatessen.  The first account (No. 0273-            
          15832) was held at Sanwa Bank (the Sanwa business checking                  
          account).  Petitioners, along with Somphob (Sam) Osathanond                 
          (petitioners' nephew who assisted in the operation of the                   
          restaurant), were signatories on this account.  The second account          
          (No. 04422-09516) was held at Bank of America.  This latter account         
          was opened on June 1, 1992, and closed on November 18, 1992.  In            
          operating the restaurant, petitioners did not deposit all cash              

               1    Petitioners also maintained personal checking and                 
          savings accounts at Sanwa Bank, Bank of America, and First                  
          Central Bank.                                                               

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