Steven K. Stoddard and Ellen M. Stoddard - Page 3

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               At the time the petition was filed, petitioners resided in             
          Anacortes, Washington (Anacortes).                                          
          Claimed Casualty Loss                                                       
               The Quissett                                                           
               During 1984, petitioners acquired a sailboat named the                 
          “Quissett” (Quissett), a 45-foot Peterson schooner made of wood             
          that was built in 1933.  At a time not disclosed by the record,             
          petitioners began to use the Quissett for charter sailing.                  
          Petitioners advertised the Quissett for charter sailing during              
               Petitioners maintained a checking account in the name                  
          “Quissett Sailing Charters” (Quissett checking account) through-            
          out the period from at least August 1993 until at least June                
          1997.  Petitioners continued to draw on that account through at             
          least the middle of 1997.                                                   
               At all times that petitioners owned the Quissett, it re-               
          quired regular repairs and maintenance.  At a time not disclosed            
          by the record, petitioners renovated the Quissett.                          
               Certain Loans Secured by the Quissett                                  
               On June 17, 1992, petitioners applied for a loan of                    
          $74,367.17 (1992 loan) from Seattle Postal Employees Credit Union           
          (Credit Union) by completing and signing a document entitled                
          application).  The purpose of that loan as stated in that loan              

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