Gabe W. Stewart, Jr., and Doris R. Stewart - Page 4

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          Community Church (Community Church) about purchasing property               
          petitioners owned in Winter Haven, Florida (Winter Haven                    
          property).  The Winter Haven property consisted of a building and           
          approximately one acre of land.                                             
               On October 16, 1996, David Collins (Mr. Collins),                      
          petitioners’ real estate agent who managed the Winter Haven                 
          property, indicated by letter to petitioners that an appropriate            
          asking price for the Winter Haven property would be “$185,000 to            
          $200,000”.  Petitioners and Community Church subsequently agreed            
          on a sales price of $200,000 for the Winter Haven property.                 
               Prior to completing the sale with Community Church,                    
          petitioners met with their accountant, Edmund Nunez (Mr. Nunez),            
          C.P.A.  Petitioners provided Mr. Nunez with a copy of the letter            
          from Mr. Collins.  Mr. Nunez suggested to petitioners that the              
          transaction with Community Church be structured as a part                   
          sale/part gift.  Mr. Nunez specifically suggested that                      
          petitioners sell the Winter Haven property to Community Church              
          for $100,000 and make a gift to Community Church of the remaining           
          $100,000.                                                                   
               On December 5, 1996, petitioners and Community Church                  
          executed the part sale/part gift arrangement.                               
               B.  The Angler Motor Boat                                              
               During 1996, petitioners owned a 1982 21-foot Angler motor             








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