Henry A. Julicher - Page 17




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          provides for 25 percent interest per year and calls for quarterly           
          payments of interest only (i.e., no principal) in the amount of             
          $3,125 beginning January 15, 1990, and ending at the end of the             
          loan term, October 15, 1994.  The First Loan Agreement also                 
          provides for fees in the event of late payments.                            
               At some point after January 15, 1990, Attieh Bros. made the            
          first payment called for by the First Loan Agreement.  Sometime             
          around March 1990, members of the Attieh family asked petitioner            
          to lend Attieh Bros. an additional $20,000.  Petitioner agreed,             
          and he sent Nidal Attieh a letter dated March 28 outlining the              
          terms of a new agreement under which the $20,000 would be added             
          to the previous principal of $50,000.  Petitioner subtracted from           
          the $20,000 certain amounts, totaling $8,000, that he felt were             
          owed him:  $3,925 for video games he had purchased on behalf of             
          Attieh Bros.; $3,125 for the next quarterly payment under the               
          First Loan Agreement, which was due April 15, 1990; and $950 in             
          late fees and interest arising from the untimeliness of the                 
          January 15, 1990, quarterly payment.  At some point in late March           
          or early April, petitioner sent Attieh Bros. the additional                 
          $12,000.                                                                    
               On April 2, petitioner and Attieh Bros. entered into a loan            
          agreement (Second Loan Agreement) that replaced and superseded              
          the first, providing for a principal amount of $70,000 (original            
          $50,000 plus additional $20,000), with an interest rate of 25               






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