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owed by June 23, 1994, in order “to avoid more interest and
penalties.”
B. Petitioners’ Attempts To Obtain a Loan
In 1994, petitioners tried three times to obtain a loan in
order to satisfy their outstanding tax liability.
Prior to April 28, 1994, petitioners applied for a $200,000
home equity line of credit from Union Bank. By statement dated
April 28, 1994, Union Bank declined to extend credit to
petitioners for the following reasons: (1) “Income insufficient
for amount of credit requested” and (2) “Excessive obligations in
relation to income”.
Prior to May 25, 1994, petitioners applied for a “home
equity line of credit increase” from First Interstate Bank. By
letter dated May 25, 1994, First Interstate Bank declined
petitioners’ application for the following reasons: (1) “Your
obligations are excessive” and (2) “Your credit history of making
payments when due is not satisfactory.”
Prior to August 5, 1994, petitioners applied for a home
equity loan from The Prudential Savings Bank, F.S.B. By notice
dated August 5, 1994, The Prudential Savings Bank denied
petitioners’ request for credit for the following reason:
“Insufficient income for amount of credit requested”.
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