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Company, Real Estate Management, Gold Distribution Company, and
Walter Killeen Company.7
In addition to the various Oak Trust accounts, petitioner
was signatory on a checking account in the name of Anthony J.
Medina, Jr. Co. at Northern Trust Company in Chicago and for part
of the year 1982 had signature authority on a checking account in
the name of Toushin & Company at Chemical Bank in New York City.8
Petitioner's Cash Transactions
On his individual Federal income tax return, Form 1040,
filed for the year 1982, petitioner reported income from wages,
capital gains from the sale of films, and rental income.9 During
1982, E & A of Illinois loaned $11,110 in cash to petitioner.
The parties have stipulated that "petitioner wrote no checks to
cash" during 1982, cashed no salary checks during that year, and
"received no cash back on deposits" in 1982.
Despite the apparent paucity of sources of cash, during the
year 1982 petitioner came into possession of relatively large
amounts of currency. He deposited $3,260 in cash into his
7The parties have stipulated copies of various bank records
as exhibits associated with these respective checking accounts.
8The parties have stipulated copies of various bank records
as exhibits associated with these respective checking accounts.
9We have determined from the stipulation that petitioner's
wages were paid by check. Since petitioner has raised no
argument to the contrary, for purposes of this motion, we will
assume that the other income items reported on the return were
also paid by check.
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