Greg R. Vinikoor and Melissa D. Vinikoor - Page 3

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          Vinikoor's grandfather.  Mrs. Vinikoor received certain shares of           
          stock as gifts from Drachman prior to her marriage to petitioner.           
               Prior to May 1, 1987, Drachman transferred 359 shares of               
          Hubbell, Inc. (Hubbell stock), 50 shares of K-Mart Corp. (K-Mart            
          stock), and 12,200 shares of Price Company (Price Co. stock) to             
          petitioners which were placed in their stock account #853-15016             
          at Merrill Lynch, Pierce, Fenner & Smith, Inc. (the account).               
          The account allowed petitioners to use credit cards and checks to           
          draw against the stock portfolio as collateral.                             
               Petitioner graduated1 from college in the spring of 1987 and           
          began a 12-month internship with Tucson Realty and Trust that               
          paid $1,000 per month.  Petitioners lived on the money in the               
          account.  At that time, petitioner had outstanding student loans            
          which Mrs. Vinikoor agreed to help pay off from the account.                
               The May 1987 account statement showed that petitioners'                
          12,200 shares of Price Co. stock had a price per share of $43.25            
          for a total fair market value of $527,650.  In addition, the May            
          1987 account statement showed petitioners had equity of $558,232,           
          expenses drawn against the account of $240,046, with a resulting            
          net equity of $318,186 in the account.                                      
               As of September 26, 1987, petitioners had 12,400 shares of             
          Price Co. stock in the account.  On October 29, 1987, 2,000                 


               1    The record does not indicate from which educational               
          institution petitioner graduated.                                           




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