Howard H. Thompson, Jr. - Page 20

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          card issued on Mr. Robinson’s American Express account.                     
               In April 1994, Mr. Robinson terminated petitioner’s arrange-           
          ment with Mr. Robinson after a dispute arose between Mr. Robinson           
          and petitioner.  In August 1995, Mr. Robinson resumed peti-                 
          tioner’s arrangement with Mr. Robinson.  That arrangement contin-           
          ued until July 18, 1996, when Mr. Robinson canceled petitioner’s            
          American Express card issued on Mr. Robinson’s American Express             
          account because petitioner failed to pay the charges that he had            
          incurred on that account.                                                   
               Weavewood’s Checks That                                                
               Were Payable to Gold Key Lease                                         
               During May and June 1996, petitioner signed the following              
          checks (collectively, Weavewood’s May and June 1996 checks and              
          individually, Weavewood’s May 15, 1996 check and Weavewood’s June           
          13, 1996 check) that were payable to Gold Key Lease (Gold Key)              
          and drawn on Weavewood’s checking account:                                  
                                 Date         Amount                                  
                             May 15, 1996    $549.99                                  
                            June 13, 1996    549.99                                   
          Petitioner used Weavewood’s May and June 1996 checks to make                
          payments to Gold Key for the lease (discussed below) of a 1995              
          Jeep Grand Cherokee (1995 Jeep Grand Cherokee).6  During January,           
          February, March, and April 1996, petitioner had paid for the                


               6Petitioner’s use of Weavewood’s May 15, 1996 check to make            
          the May 15, 1996 lease payment for the 1995 Jeep Grand Cherokee             
          was the payment of a personal expense of petitioner.                        





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