Phyllis E. Campbell - Page 3

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          commodities account in petitioner’s name at Refco, Inc. (Refco),            
          a trading clearinghouse.  Mr. Campbell stated that he transferred           
          approximately $100,000 to petitioner’s account every few months.            
          Petitioner’s Assets and Liabilities                                         
               On or about February 1, 1983, the Campbells purchased a home           
          in Naperville, Illinois, for $321,000.  On August 16, 1982, Mr.             
          Campbell had transferred $1 million to petitioner’s personal                
          account from profits in petitioner’s Refco account by securing a            
          check from Refco issued to petitioner for that amount.                      
          Petitioner used those funds to purchase the home and several                
          certificates of deposit.  The house was not subject to a mortgage           
          loan.  Petitioner and Mr. Campbell resided in the Naperville home           
          from February 1 through December 31, 1983.  Sometime in 1990, the           
          Campbells sold one of two lots on which the Naperville home was             
          located for approximately $165,000.  In 1993, they sold the                 
          remaining lot for approximately $393,000.  In 1990, the Campbells           
          purchased a home in petitioner’s name in Lampe, Missouri (the               
          Lampe home), for approximately $181,000.  The Lampe home has                
          remained an asset exclusively owned by petitioner.  They used               
          some of the proceeds from the sale of the Naperville property to            
          purchase the Lampe home.                                                    
               As of the end of the taxable year 2000, petitioner had an              
          individual retirement account with a fair market value of                   
          $35,833.  As of August 14, 2003, there has been no mortgage or              






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