Bruno and Francesca Tabbi - Page 11

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                    Amount                   Source of funds                          
                    $50,002.78          Americana                                     
                    30,268.57           sale of real estate owned by                  
                                        petitioners and/or Americana                  
                    7,229.75            petitioner husband's income                   
                    1,907.00            installment income from sale of               
                                        real estate                                   
                    2,707.00            Schedule E rental income                      
                     3,110.00           petitioners' bank accounts                    
          Total:  $95,225.10                                                          
               Petitioner husband used $53,265.84 from the escrow account             
          in 1987 to pay petitioners' personal expenses and expenses                  
          relating to various real properties owned by petitioners and/or             
          Americana.                                                                  
               Petitioner husband made several deposits of currency of more           
          than $100 in 1987.                                                          
               Petitioner husband deposited income he earned in 1987 and              
          1988 in bank accounts in petitioner wife's name.  She used these            
          bank accounts to pay personal and household expenses.                       
               c.   1988                                                              
               Petitioner husband earned commissions of $14,621.84 in 1988            
          from the sale of two residences in Rochester, Michigan.                     
          Petitioner husband cashed the two commission checks at the East             
          Side Market, and deposited the cash.  Petitioner husband made               
          several other large (i.e., more than $1,000) deposits of currency           
          in 1988.                                                                    
               Petitioner husband deposited the following amounts in 1988:            
          Account          Type of Income             Amount                          
          Petitioner wife       commissions       $7,888.00                           
          Petitioner wife       other                    4,651.58                     
          Canta                 commissions             69,242.26                     
          Canta                 refunds                    403.50                     




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