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During the years in issue, petitioners purchased
seven parcels of real property in Mrs. Bacon’s name as follows:5
Balance Paid
at Closing Cash paid
Purchase Date Purchase Price Net of Loans at Closing1
1. 02/23/88 2$412,000 $3,167 $3,167
2. 03/04/88 3585,000 285,000 ---
3. 03/31/89 195,000 197,017 74,285
4. 06/18/90 425,000 25,000 ---
5. 06/29/90 530,000 152,285 ---
6. 07/02/90 134,000 4131,592 530,591
7. 10/18/90 250,000 35,528 5,528
Total 2,531,000 829,589 113,571
1Cash amounts are included in the balance paid at closing amounts.
2During 1988, petitioners paid down a $287,069 first mortgage on this
property by $283,310. See appendix C.
3Mrs. Bacon executed a $300,000 promissory note secured by a mortgage on
the property. The $300,000 purchase money note and mortgage required 36
monthly payments of $2,518 and a balloon payment of $288,988 at the end of the
36 months. Monthly payments of $2,518 were made by Mrs. Bacon, or on her
behalf, for 36 months and the balloon payment of $288,988 was also paid by
Mrs. Bacon, or on her behalf, at the end of 36 months. See appendix C.
4Part of the purchase price was paid with a check in the amount of
$55,000 purchased with $17,000 in funds withdrawn from Radtam’s savings
account at Chemical Bank, account No. 600-871255, $28,000 in funds withdrawn
from petitioners’ personal savings account maintained at Chemical Bank,
account No. 623503349, and a check in the amount of $10,000 drawn on
petitioners’ personal checking account at the same institution. Additionally,
$35,000 of the purchase price was paid by a check drawn on petitioners’
personal checking account at Barnett Bank, $5,000 by a check drawn on
petitioners’ personal checking account at First Fidelity Bank, $20,000 by a
check purchased from Security Savings & Loan, in part with $19,000 in cash
tendered to the bank by petitioners on July 2, 1990, and a check in the amount
of $5,000, drawn on the account of Thomas Begley, Jr. Esq., from funds
deposited in the same account earlier in 1990.
5Includes $10,000 in cash and $1,591 in coin deposited in the account of
Burlington County Abstract Co. at closing and $19,000 in cash tendered to
Security Savings & Loan by petitioners on July 2, 1990, in part, to purchase a
$20,000 check. ($10,000 + $1,591 + $19,000 = $30,591.)
On or about October 19, 1989, petitioners paid Collective
Federal Savings Bank $10,657 to modify the terms of their loan
agreement on property located at 218 E. 18th Street, North Beach
5See appendix C for details.
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