Herschel H. and Roberta S. Hoopengarner - Page 6

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               In 1983, the property was foreclosed upon.  The foreclosure            
          proceeds totaled $2,063,113.                                                
          E.   Cowan Avenue Property                                                  
               The Cowan Avenue property, located in Irvine, California,              
          was initially owned by the H & H partnership.  On October 19,               
          1978, petitioners and the Hornbeaks recorded a grant deed for a             
          purchase price of $676,000.  On August 30, 1979, a deed of trust            
          was recorded securing a loan on the property in the amount of               
          $745,000.  On September 3, 1981, a collateral assignment of                 
          leases was recorded securing a debt in the amount of $2,850,000.            
          Also on September 3, 1981, a deed of trust with assignment of               
          rents was recorded to secure a debt of $942,500.                            
               In 1982, the property was foreclosed upon.  A trust deed of            
          sale was recorded in satisfaction of the debt for $450,000                  
          consideration received.                                                     
          F.   Avenida Del Mar Property                                               
               On January 16, 1981, petitioner and Grant Hornbeak acquired            
          the Avenida Del Mar property in San Clemente, California, for a             
          purchase price of $540,000.  Concurrently, a deed of trust was              
          recorded securing a loan of $375,000.  On March 17, 1981,                   
          petitioner and Grant Hornbeak obtained a loan of $600,000,                  
          secured by a deed of trust on the property.  Concurrently, a deed           
          of trust in full reconveyance by the Bank of San Clemente was               
          recorded, which related to the property.  On May 18, 1982, a                






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