Richard J. Salem and Eileen L. Salem - Page 9

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               Mr. Martin presented a request for the approval to                     
               change the borrower on the $1.1 million in loans to                    
               Salem, Saxon & Nielsen, P.A. to the names of Richard J.                
               Salem, Bernice S. Saxon, and Richard A. Nielsen based                  
               on their pro-rata share ownership of the firm. * * *                   
               Mr. Martin indicated that as a result of an IRS audit                  
               the firm is undergoing, the partners are being                         
               questioned regarding the basis of their individual                     
               ownerships in the corporation.  He mentioned that the                  
               P.A. will hypothecate its assets as collateral for the                 
               notes to the partners.  He indicated that we will                      
               continue to have a $700M assignment of life insurance                  
               on Mr. Salem.  He mentioned that Mr. Salem owns 85%,                   
               Ms. Saxon owns 10%, and Mr. Nielsen owns 5% of the                     
               firm. * * *                                                            
          C.   Gulf Properties of Pinellas County, Florida III, Inc.                  
               Mr. Salem owned a one-third interest in an S corporation               
          known as Gulf Properties of Pinellas County, Florida III, Inc.              
          (Gulf Properties).  On June 30, 1988, Gulf Properties purchased             
          property located at 300 Gulf Boulevard, Belleair Shores, Florida            
          (300 Gulf Boulevard), for the purchase price of $600,000.  On               
          December 28, 1990, Gulf Properties transferred title of 300 Gulf            
          Boulevard to Mr. Salem, subject to a mortgage in the amount of              
          $530,900.  Between 1987 and 1992, real property values dropped              
          significantly in the area of 300 Gulf Boulevard.                            
          D.   Petitioners' Income Tax Returns                                        
               The Salems filed a joint income tax return (Form 1040) and             
          an amended return (Form 1040X) for the taxable year 1990.  The              
          Salems reported a net operating loss for 1990 in the amount of              
          $192,546.  In computing the 1990 net operating loss, the Salems             
          included the $221,140 loss from SS&N.  The Salems did not report            





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