Charles R. Harp and April B. Harp - Page 11

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                    from their accounts:  (1) Payments to K & H in the amount of                                                                                           
                    $52,462 and (2) payments of K & H expenses in the amount of                                                                                            
                    $3,693.40.  During 1990, the aggregate amount of K & H's funds                                                                                         
                    and Ms. Velilla's funds that petitioner deposited into petition-                                                                                       
                    ers’ accounts at Washington Federal and Benjamin Franklin Federal                                                                                      
                    exceeded the aggregate amount that petitioners paid to, or for                                                                                         
                    the benefit of, K & H and Ms. Velilla by $60,168.06.                                                                                                   
                              Miscellaneous Deposits                                                                                                                       
                                                                                                                                                                          
                              During 1989, in addition to the deposits of K & H's and Ms.                                                                                  
                    Velilla's funds that are at issue for that year, certain deposits                                                                                      
                    that respondent concedes do not constitute unreported income for                                                                                       
                    that year, and one deposit that petitioners concede constitutes                                                                                        
                    unreported income for that year,5 petitioners made various depos-                                                                                      
                    its totaling $83,364 (miscellaneous deposits) that are at issue                                                                                        
                    for 1989, including a deposit of $6,222.89 on May 30, 1989, into                                                                                       
                    petitioners' account at Washington Federal.  The record does not                                                                                       
                    disclose and/or explain the nature or sources of those miscella-                                                                                       
                    neous deposits.                                                                                                                                        
                              During 1990, in addition to the deposits of K & H's and Ms.                                                                                  
                    Velilla's funds that are at issue for that year and certain                                                                                            
                    deposits that respondent concedes do not constitute unreported                                                                                         
                    income for that year, petitioners made various miscellaneous                                                                                           


                    5  Petitioners concede on brief that a $2,500 deposit on Apr. 24,                                                                                      
                    1989, of the proceeds from the sale of plans constitutes unre-                                                                                         
                    ported income for 1989.                                                                                                                                




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