Robert Lee and Rebecca Waters - Page 5




                                        - 4 -                                         
               In March 1987, the land contract vendees received a warranty           
          deed to the Hazelwood property.  The warranty deed recites that             
          the Hazelwood property was conveyed for the “full consideration”            
          of $55,000.                                                                 
               In October 1988, Marland and Dortha Moore and Marland                  
          Moore’s mother conveyed their interest in the Hazelwood property            
          to petitioners and petitioner’s father.  According to the quit              
          claim deed, the conveyance was for the “full consideration” of              
          $50,000.                                                                    
          C.  Mortgage on the Hazelwood Property                                      
               In February 1990, a loan in the amount of $70,000 was                  
          obtained from First Independence National Bank of Detroit (First            
          Independence).  As security for the loan, petitioners and                   
          petitioner’s father gave First Independence a mortgage on the               
          Hazelwood property.                                                         
          D.  Rental of the Hazelwood Property                                        
               In or about May 1994, petitioner3 purportedly entered into a           
          lease with a nonprofit housing corporation, operated by Reverend            
          Jim Holley, which converted the Hazelwood property into a                   
          homeless shelter.  This arrangement allegedly ended in February             
          or March 1996, at which time petitioner took back possession of             



               3  For the sake of convenience, we may sometimes refer to              
          petitioner as the owner of the Hazelwood property even though               
          petitioners and petitioner’s father were the record owners of the           
          property.                                                                   





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