Thomas J. Rosser - Page 6




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                         Loan      New Funds or Replacement Note                      
                                        1989                                          
                         $10,000   replacement note                                   
                                        1990                                          
                         $5,000    replacement note                                   
                                        1991                                          
                         $20,000   new funds                                          
                         45,000    replacement note                                   
                         10,000    new funds                                          
                         5,000     replacement note                                   
                         10,000    replacement note                                   
                                        1992                                          
                         $35,000   new funds                                          
                         53,000    replacement note                                   
                         10,500    replacement note                                   
                         30,000    replacement note                                   
                         10,000 new funds                                             
                         105,000   replacement note                                   
                         15,000    replacement note                                   
                         25,000    replacement note                                   
                                        1993                                          
                         17,939    replacement note                                   
                         21,000    new funds                                          
                         15,000    replacement note                                   
                         20,000    new funds                                          
               Petitioner borrowed $1,500 in 1992 and $20,000 in 1993 that            
          he used for the Sunbury building in a manner not described in the           
          record.1  The record does not show how much interest petitioner             
          paid on these loans in the years in issue.  Petitioner also                 
          borrowed money to invest in a limited partnership that owned a              
          nursing home called the Heritage Inn.  In 1993, petitioner paid             


               1  The parties stipulated that these are “replacement                  
          notes”.  However, the record does not indicate which loans these            
          notes replaced.                                                             





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