- 38 - balance of the estimated $225,000 fair market value of lot 12 (i.e., $45,000) was to be reflected as a loan from petitioners to Edward O’Malley on which Edward O’Malley was not required to make any payments; (6) petitioners were to pay all the expenses relat- ing to lot 12, including all real property taxes; and (7) Edward O’Malley was to retransfer lot 12 to petitioners after a five- year period. On June 14, 2000, pursuant to the agreement between Edward O’Malley and Mr. O’Malley, (1) petitioners entered into a trans- action with Edward O’Malley with respect to lot 12 that was structured in the form of a sale of lot 12 by petitioners to Edward O’Malley; (2) Edward O’Malley borrowed $180,000 from F&M Bank and secured that loan with lot 12; and (3) Edward O’Malley transferred to petitioners all but $8,475 of the $180,000 F&M Bank 2000 loan, or $171,535.34 Pursuant to the agreement between Edward O’Malley and Mr. O’Malley, as modified by them when Edward O’Malley agreed to refinance the $180,000 F&M Bank 2000 loan, petitioners made from July 2000 through December 2005 payments totaling $69,538.49 to F&M Bank on the $180,000 F&M Bank 2000 loan or the refinanced F&M Bank 2000 loan. Pursuant to the agreement between Edward O’Mal- ley and Mr. O’Malley, as modified by them when Edward O’Malley agreed to refinance the $180,000 F&M Bank 2000 loan: (1) From 34See supra note 15.Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 NextLast modified: November 10, 2007