-204-                                                   
            does not include loan documents or notes evidencing the loans to                            
            Ballard, Lisle, and their grantor trusts.                                                   
                  At the end of 1987, IRA sold its IFI stock to Gallenberger                            
            for $1.  Exh. 5912, at 7 (AJE 6).  In addition to receiving the                             
            IFI stock, Gallenberger was given $3,000 identified as accounting                           
            fees.  Exh. 9020; Exh. 35, at 12.  IRA claimed a long-term                                  
            capital loss of $65,000 attributable to this transaction on its                             
            1987 tax return.  Exh. 22, Schedule D.                                                      
                  In March 1989, approximately 2 years after IFI transferred                            
            receivables of $1,120,889 to IRA, IFI filed for bankruptcy.  Exh.                           
            627.  At the time of the bankruptcy filing, Gallenberger was                                
            IFI’s vice president, and she owned 100 percent of its stock.  At                           
            the time of IFI’s bankruptcy, IFI owed debts to the following                               
            creditors:                                                                                  
                  Creditor          Reason           Amount of Claims                                   
                  IRS             1984 taxes              $5,500                                        
                  Kanter          Legal services             750                                        
                  Neal, Gerber                                                                          
                  & Eisenberg   Legal services             550                                          
                  PSAC            Services                   700                                        
                  I&F Corp.       Services                   775                                        
                 Total                                  8,275                                          
            Exh. 627.                                                                                   
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