Herschel H. and Roberta S. Hoopengarner - Page 5

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          C.   K-Mart Property                                                        
               On December 26, 1980, petitioners, Grant Hornbeak, and                 
          others purchased real estate located in Las Vegas, Nevada, for              
          $605,000 to construct a K-Mart.  On May 17, 1982, the property              
          was transferred to the H & H partnership.  On August 10, 1982, a            
          portion of the property was sold for $239,000.  Petitioner                  
          testified that he did not recall whether the proceeds from the              
          sale were reinvested in the property for improvements.  On                  
          September 22, 1983, Grant Hornbeak transferred his interest in              
          the property to petitioner for $127,500.                                    
               Between 1982 and 1984, loans were taken against the property           
          in the amounts of $670,000, $5,800,000, and $995,000.                       
               In 1985, the property was foreclosed upon.  The foreclosure            
          proceeds totaled $6,606,398.                                                
          D.   Indio Property                                                         
               H & H Land Development Corp. purchased the Indio property,             
          located in Riverside County, California, for $1,590,000.  The               
          purchase price was secured by three deeds of trust.  On August 1,           
          1980, and March 3, 1981, H & H Land Development Corp. recorded              
          additional deeds of trust in the amounts of $1,227,912 and                  
          $221,000, respectively.                                                     
               On February 9, 1982, H & H Land Development Corp. sold a               
          portion of the property for $54,000.                                        








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