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The bank statements provided to petitioners’ accountant were
primarily for two accounts at Security Savings & Loan. Yet
Radtam maintained a savings account at Chemical Bank25 from July
1, 1988, through June 30, 1992. It was not until after the
commencement of the examination by respondent that petitioners’
accountant learned that Radtam had a savings account with
Chemical Bank.
Mrs. Bacon prepared annual summaries of personal income
sources and expenses relating to petitioners’ real estate, which
she gave to their accountant. Mrs. Bacon also provided the
accountant with Forms 1099 and settlement sheets from each real
estate purchase.
During the years in issue, petitioners transferred
$1,478,399 from two Radtam accounts and deposited $590,689 in
cash into their personal accounts. Despite the significant
deposits into petitioners’ personal accounts, Mrs. Bacon did not
disclose these deposits or provide personal bank statements to
their accountant.
On or about January 6, 1992, Mr. Bacon filed an application
for a VISA card listing his occupation as tavern owner of Radtam
Inc. t/a Jug Handle Inn and listed his annual salary as $299,000.
However, Mr. Bacon never reported receiving any salary or
25Account No. 600-871255.
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