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Virginia Ferguson (Ms. Ferguson) resided in Fridley, Minnesota,
and Mr. Jacobsen and Donna M. Cleare-Jacobsen (Mrs. Jacobsen)
resided in Apple Valley, Minnesota. Hereinafter, references to
petitioners are to Messrs. Del Bosque and Jacobsen.
On December 31, 1986, petitioners each owned two
snowmobiles--a 1987 Polaris Indy 600 and a 1987 Polaris Indy
Sport. Petitioners each purchased the 1987 Polaris Indy 600s
from Metro-North Sports on October 15, 1986, for the base price
of $4,688; two items identified as “north country” were purchased
at the same time for $469 each. The record does not disclose
when the 1987 Polaris Indy Sports were purchased; however, a
receipt from Metro-North Sports shows that, on October 29, 1986,
petitioners purchased accessories and parts for two “Indy 600s”
and two “Sports”. Mr. Jacobsen disposed of his Sport in 1988.
In December 1986, Mrs. Jacobsen made a $2,000 loan to her
employer. This loan was repaid in 1987.
Mrs. Jacobsen had a Chase Manhattan “money market with
checks” account (the MMWC account). On December 31, 1986, the
balance in that account was $8,618.
In 1986, Mrs. Jacobsen received an inheritance of $12,518
plus a one-eighth interest in a contract for deed valued at
$1,966.
On December 31, 1986, Mr. Del Bosque had $12,000 in an
account with First Bank East. In January 1987, he used funds
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