Michael J. Downing and Sandra M. Downing - Page 16

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               2.  The Vehicles                                                       
               On December 6, 1994, Michael bought a new Ford F250 truck              
          for the plumbing business.  He paid $2,100 in cash and financed             
          the remaining $22,261.30 at an interest rate of 9.9 percent, with           
          monthly payments of $471.83.  In 1995, petitioners made payments            
          on this loan totaling $5,662.  Of this total, petitioners paid              
          $1,200 by check and $4,462 in cash.  See supra note 2, as to                
          respondent’s concessions.  Michael continued to use the truck for           
          business purposes in 1995.                                                  
               On August 15, 1995, Michael bought a 1993 500SL Mercedes-              
          Benz for $85,311.  He did not make a downpayment.  He financed              
          the car at an interest rate of 13.25 percent, with monthly                  
          payments of $1,449.73.                                                      
               On September 1, 1995, Michael bought a 1994 C2 3.6 Porsche             
          for $108,630.61.  Again, he did not make a downpayment.  He                 
          financed the car at an interest rate of 13.1 percent, with                  
          monthly payments of $1,775.26.                                              
               A Mercedes-Benz that had been bought by one or both of the             
          petitioners in 1992 or 1993, was stolen in 1994 or 1995.                    
               3. Cash Advances                                                       
               On May 30, 1994, petitioners withdrew a $2,500 cash advance            
          from their American Express Optima account.  On August 12, 1994,            
          petitioners withdrew a $3,000 cash advance from their First USA             
          Visa account.  On March 21, 1995, petitioners deposited a $5,000            







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