Nancy B. Doyle - Page 8




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          petitioner’s husband.  On October 7, 1993, this check was                   
          endorsed and deposited into the Michele/Denise Doyle bank account           
          No. 2.                                                                      
               On December 23, 1993, petitioner’s husband liquidated an               
          investment interest in Colonial Properties Services, Inc.  The              
          liquidation proceeds were received in the form of a check in the            
          amount of $5,543.88.  On December 30, 1993, this check was                  
          endorsed and deposited into the Michele/Denise Doyle bank account           
          No. 2.                                                                      
               On June 10, 1994, petitioner and her husband completed and             
          signed Form 433-A, Collection Statement for Individuals.  On this           
          form, the Doyles understated the value of their home; they listed           
          its value as $90,000 even though in February 1993, they had                 
          obtained a $97,500 mortgage on the property.                                
               On December 24, 1994, $8,845.73 was deposited into the                 
          Michele/Denise Doyle bank account No. 1, $8,000 of which was cash           
          and the balance of which consisted of three checks from                     
          Wellington Power Corp., made payable to petitioner, and one check           
          from Parker & Parsley Partnership Distribution Account, made                
          payable to petitioner and her husband.  On December 27, 1994,               
          $8,900 of funds belonging to petitioner and her husband was                 
          deposited into the Michele/Denise Doyle bank account No. 2.                 










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