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20, 1984, Leroy Campfield, petitioner's brother, gave Wilkes
Williams (Williams), also with Robinson Real Estate, $5,000 in
cash to be applied to the purchase price of the Route 21
property. Along with the $5,000 in cash, Leroy Campfield
delivered to Williams a purchase contract signed by petitioner.
The sale of the Route 21 property closed on or about January
18, 1985. At the closing, petitioner produced a $50,000
cashier's check, No. 14430953, dated January 9, 1985, and a
briefcase containing $47,000 in cash to be applied to the
purchase price. The entire $47,000 in cash consisted of $20
bills. Williams helped count the $47,000, and, because only
$45,000 was needed to close the sale, $2,000 was returned to
petitioner.
Petitioner financed $50,000 of the Route 21 property
purchase with a 90-day note given to the sellers, payable on
April 15, 1985. Petitioner satisfied the note in 1985 with a
$52,417.12 trustee check drawn on the client account of attorney
James M. Kearns (Kearns). Kearns assisted petitioners with their
real estate activities, among other things.
After the closing on the Route 21 property, Williams
deposited the $45,000 in cash, along with cashier's check No.
14430953, at a local bank. An employee of the bank informed
Williams that, because the deposit involved over $10,000 in cash,
the bank would notify the Internal Revenue Service (IRS) about
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