Herschel H. and Roberta S. Hoopengarner - Page 7

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          $550,000 loan was obtained, secured by a deed of trust on the               
          property.                                                                   
               On January 27, 1982, a notice of default was recorded                  
          pertaining to the $375,000 loan.  On June 17, 1982, a deed of               
          trust was recorded securing a note of $900,000.                             
               In 1984, the property was foreclosed upon.                             
          G.   Business Center Drive Property                                         
               On April 27, 1976, the property located at Business Center             
          Drive, Irvine, California, was assigned to petitioner for $67,500           
          in consideration.  On October 16, 1978, petitioner obtained a               
          loan in the amount of $675,000.  On June 26, 1979, a deed of                
          trust was recorded, securing a loan in the amount of $100,000.              
               Allan Silverman, a business acquaintance of petitioner, took           
          out a loan of $493,250 and gave the funds to petitioner to repay            
          a different loan on the property.  Allan Silverman’s loan was               
          partially secured by the Business Center Drive property.  On                
          October 5, 1990, according to the schedule prepared by Revenue              
          Agent John Grennan regarding this property, petitioner                      
          transferred a 50-percent interest in the property to Allan                  
          Silverman.  Petitioner collected the rents on the Irvine Business           
          Center property and kept the money for himself instead of paying            
          the bank or Allan Silverman on the loan.                                    
               In 1992, the property was foreclosed upon.                             








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