Jacob R. Ramsburg, Jr. and Norma J. Ramsburg - Page 7

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               Kildare Timmy did not execute a note with respect to either            
          of the Frederick Underwriters’ 1992 loans to Mr. Ramsburg.                  
          Kildare Timmy did not make any payments of principal to Mr.                 
          Ramsburg or Frederick Underwriters with respect to either of such           
          loans.                                                                      
               On December 31, 1994, Mr. Stottlemeyer executed a document             
          entitled “NOTE” (Mr. Stottlemeyer’s note)6 that provided in                 
          pertinent part:                                                             
                    I Carroll K. Stottlemeyer, after date, FOR VALUE                  
               RECEIVED, the Undersigned, jointly and severally,                      
               promise to pay to the order of Jacob R. Ramsburg Jr.,                  
               the lesser of my share of cash proceeds from disposi-                  
               tion of horses owned by the entity known as Kildare                    
               Timmy or the sum of one hundred fourty six thousand                    
               seven hundred and fifty Dollars payable at the offices                 
               of Frederick Underwriters, with interest from date at                  
               the rate of 0% per annum.  [Reproduced literally.]                     


               5(...continued)                                                        
          failed to carry their burden of showing, that Frederick Under-              
          writers did not make the Frederick Underwriters’ 1995 loans to              
          Mr. Ramsburg in his individual capacity, that Mr. Ramsburg did              
          not sign Mr. Ramsburg’s 1995 notes in his individual capacity,              
          and that he did not transfer the proceeds of Frederick Underwrit-           
          ers’ 1995 loans to Mr. Ramsburg to Kildare Timmy as capital                 
          contributions.  In any event, whether (1) Frederick Underwriters’           
          1992 loans to Mr. Ramsburg and Mr. Ramsburg’s 1992 notes or                 
          (2) Frederick Underwriters’ 1995 loans to Mr. Ramsburg and Mr.              
          Ramsburg’s 1995 notes were outstanding at the end of 1997 and on            
          the next day (i.e., Jan. 1, 1998) on which Kildare Timmy distrib-           
          uted all of its assets to Mr. Ramsburg does not affect our                  
          findings and conclusions herein.  For convenience, we shall                 
          hereinafter refer only to Frederick Underwriters’ 1992 loans to             
          Mr. Ramsburg and Mr. Ramsburg’s 1992 notes.                                 
               6By using the term “Mr. Stottlemeyer’s note”, we do not                
          intend to suggest that for tax purposes there was a loan by Mr.             
          Ramsburg to Mr. Stottlemeyer.                                               




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