Joseph Alan Piole - Page 5




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               During August 1987, petitioner purchased from Kim C. and               
          Mary P. Hammill a building located at 1939 Babcock Boulevard,               
          Pittsburgh, Pennsylvania (the Babcock building or property).  The           
          sale price of the Babcock property was $55,000.  In November                
          1987, petitioner paid $25,000 in cash to Kim C. Hammill in                  
          partial payment of the amount due on the Babcock property.  The             
          balance of the sale price, $30,000, was the subject of a seller-            
          financed mortgage on the property.  Petitioner paid $50 for the             
          recording of the deed and mortgage for the Babcock property, and            
          $300 for Pennsylvania transfer taxes.                                       
               As of December 31, 1987, petitioner owed $29,556.95 on the             
          Babcock property.  During 1988, petitioner made monthly cash                
          mortgage payments of $396.45 to the Hammills.  In September 1988,           
          petitioner used cash to pay off the balance due on the Babcock              
          property.                                                                   
               Petitioner maintained an apartment on the second floor of              
          the Babcock building and operated a taxidermy business, known as            
          the Wilderness Taxidermy Studio (Wilderness Taxidermy), on the              
          first floor of the building.                                                
          During 1987, petitioner opened checking account No. 1534-119                
          in his name at Equibank.  As of December 31, 1987, 1988, 1989,              
          1990, and 1991, petitioner’s Equibank checking account had                  
          balances of $1,414.53, $909.99, $645.50, $396.24, and $289.76,              
          respectively.                                                               






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