$4,913 and $4,358, respectively, were drawn from this
account.
On April 15, 1983, petitioner opened an individual
retirement account at United Jersey Bank in her name and
deposited $500 into the account. Additional deposits of
$2,000 were made into the account during each of the years
in issue, 1985 and 1986. The balance of the account on
April 30, 1994, was $8,150.52.
Similarly, on April 15, 1983, Mr. DiMichele opened an
individual retirement account at United Jersey Bank and
deposited $1,750 into the account. He made additional
deposits of $2,000 into the account during each of the
years in issue.
On May 31, 1984, petitioner opened a bank account
under her maiden name, Eileen Secatore, at Home Unity
Savings & Loan. She initially deposited $56,057.78,
consisting of the insurance proceeds from the fire in
petitioners' home in 1983. On May 11, 1987, petitioner
and her husband withdrew $25,000 from the Home Unity
account, and on June 16, 1987, they withdrew $33,000 more
from the account. On June 18, 1987, petitioner opened an
account at United Jersey Bank, in her maiden name, Eileen
Secatore, and made an initial deposit of $33,000.
At about the time of the Government's investigation
into Mr. DiMichele's affairs, petitioners owned the
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