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and that mortgage loan was completely paid off by December 22,
1992.
During August 1995, petitioner obtained from World Savings
and Loan Association another mortgage loan on the Neponset
property in the amount of $65,000. According to the application
for that mortgage loan, the purpose of the loan was to acquire
farmland in Tennessee.
On or about August 14, 1995, after respondent had commenced
collection activity against petitioner and Ms. Leggett for the
civil penalties, petitioner purchased real property in Tennessee
(Tennessee property) for approximately $130,000. Petitioner
titled that property in the name of Young Farm Trust, Frank
Starling Trustee. The Tennessee property was not incumbered by
any mortgages. On or about February 13, 1997, the Young Farm
Trust, Frank Starling Trustee, transferred the Tennessee property
back to petitioner and Ms. Leggett for no consideration.
On March 20, 1996, after respondent had commenced collection
activity against petitioner and Ms. Leggett for the civil pen-
alties, petitioner and Ms. Leggett conveyed the Neponset property
to Michael T. Morgan for no consideration. On June 5, 1996, a
notice of Federal tax lien was filed with the Clerk of the
Circuit Court for Orange County, Florida, for taxes owed by
Michael T. Morgan. Shortly thereafter, on June 17, 1996, Michael
T. Morgan transferred the Neponset property back to petitioner
and Ms. Leggett for no consideration.
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