Larry J. and Angela L. Siggelkow - Page 2




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          the ordinary course of Mr. Siggelkow’s business, he made a bona             
          fide loan to a company he partially owned that became a worthless           
          business debt in 1992 when the company went out of business.                
          Respondent disputes that the advance of funds was made in the               
          course of petitioner's trade or business.                                   
                                  FINDINGS OF FACT                                    
               The stipulation of facts and the exhibits attached thereto             
          are incorporated herein by this reference.                                  
               Petitioners Larry and Angela Siggelkow, husband and wife,              
          resided in Las Vegas, Nevada, at the time their petition was                
          filed.  Angela Siggelkow is a petitioner in this case because she           
          joined in filing returns with Larry Siggelkow.  Subsequent                  
          references to “petitioner” refer only to Larry Siggelkow.                   
               During the tax year in question, petitioner owned one-third            
          of the stock in PLG Enterprises, Inc., d.b.a. Eagle Jet Charter,            
          Inc. (PLG), and all of the stock in Lang Aire, Inc. (Lang), as              
          well as interests in other aviation-related companies.                      
               In May 1992, petitioner borrowed $255,000 from Clark County            
          Credit Union (CCCU) against funds held in his personal accounts             
          at CCCU.  The CCCU loan agreement specified a 5.75-percent                  
          interest rate with a single balloon payment due in June 1993.               
          Petitioner instructed the credit union to wire the funds directly           
          to AIG Aviation Insurance Services, Inc. (AIG), on behalf of PLG            
          as payment for its successful bid to buy a salvaged Lear jet held           


               1(...continued)                                                        
          and Procedure.                                                              

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