Paul Mifsud and Maria G. Mifsud - Page 19




                                       - 19 -                                         

               Respondent issued a notice of deficiency (notice) to pe-               
          titioners with respect to their taxable years 1992, 1993, and               
          1994.  In the notice, respondent determined, inter alia, that               
          petitioners had unreported income for 1992, 1993, and 1994 in the           
          amounts of $60,034, $53,094, and $57,891, respectively, the                 
          likely source of which was Paul & Joe, Inc.  In making those                
          determinations, respondent relied on an analysis under the bank             
          deposits method of petitioners' bank deposits during the years at           
          issue, which showed that petitioners had unexplained bank de-               
          posits during those years.  Respondent further determined in the            
          notice that the cost of goods sold reported by Paul & Joe, Inc.,            
          for 1993 and 1994 was understated in the amounts of $16,515 and             
          $19,637, respectively, because Mr. Mifsud made purchases for Paul           
          & Joe, Inc., during those years, which were not reimbursed by               
          that company.3  In the notice, respondent determined that pe-               
          titioners had deficiencies in tax (and underpayments) for 1992,             
          1993, and 1994 in the amounts of $18,087, $15,653, and $17,073,             
          respectively.  Respondent further determined in the notice that             
          petitioners are liable for each of the years at issue for the               
          fraud penalty under section 6663 on the entire amount of each               
          such underpayment.                                                          


               3  The notice indicates that no adjustment was made to cost            
          of goods sold for 1992 because no information was available for             
          that year.                                                                  





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