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determined that the fair market values of the properties securing
petitioner's loans were less than the amounts owed on the
properties and abandoned them in bankruptcy. Both properties
were sold at foreclosure on July 24, 1992, in order to pay the
senior secured creditor.
The Unsecured Swift Loan
For $4,500 petitioner obtained from Jed Wilbourn a note for
$5,000 made by Gerald Swift in 1991. On October 18, 1993,
petitioner became a judgment lien creditor of Gerald and Jolynn
Swift in the amount of $20,000 with respect to the advancement to
them of loan proceeds of $15,000 in 1991.
In 1996, the Swifts filed a petition for bankruptcy.
Petitioner filed a proof of claim for both notes with the
bankruptcy court.
Personal Loans
Wooton
Petitioner lent his friends Lorenzo and Betty Wooton $4,000
for which they executed a note to him for $4,400. In June of
1991 the Wootons issued to petitioner in payment of the loan a
check for $4,000 that was dishonored for nonsufficient funds.
Rawoof
Petitioner lent his friend Mohamed Rawoof $5,000 on January
11, 1991, to pay for utilities for apartment buildings he owned
in New York. In December of 1993, Mr. Rawoof petitioned for
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