Steven K. Stoddard and Ellen M. Stoddard - Page 5

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          application (1994 loan application).  The purpose of that loan as           
          stated in that loan application was boat repair.  The 1994 loan             
          application indicated, inter alia, that the Quissett was to                 
          secure5 the 1994 loan and that the value of the Quissett was                
          $170,000.  Petitioners’ loan balance with Credit Union before               
          they received the 1994 loan was $89,195.63, and their loan                  
          balance with Credit Union after they received that loan was                 
               Foreclosure With Respect to Credit                                     
               Union Loan Secured by the Quissett                                     
               On November 12, 1996, petitioners filed a petition for                 
          bankruptcy (bankruptcy petition) under Chapter 7 of title 11 of             
          the United States Code with the United States Bankruptcy Court              
          for the Western District of Washington (bankruptcy court).                  
          Petitioners’ bankruptcy petition included a document entitled               
          “SUMMARY OF SCHEDULES”, to which was attached, inter alia,                  
          “SCHEDULE B-–PERSONAL PROPERTY” (bankruptcy Schedule B) and                 
          “SCHEDULE D--CREDITORS HOLDING SECURED CLAIMS” (bankruptcy                  
          Schedule D).                                                                
               In bankruptcy Schedule B, petitioners listed the Quissett              
          among their personal property and claimed that it had a fair                
          market value of $84,000.                                                    

               5The terms of the security agreement that petitioners en-              
          tered into by signing the 1994 loan application were on the                 
          reverse side of that document.  The record does not contain a               
          copy of the reverse side of the 1994 loan application and the               
          terms of that security agreement.                                           

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