- 3 -
of income in their 1992 return (reported income). The reported
income consisted of $4,345 of income from petitioner Joseph M.
Kawal's part-time work for Linden Lumber and Home Center (Linden
Lumber), $4,568.38 of income from petitioner Sybil G. Kawal's
work for Best Care Agency (Best Care), and $25 of interest
income. During 1992, Linden Lumber paid petitioner Joseph M.
Kawal in cash and Best Care paid petitioner Sybil G. Kawal by
check.
During 1992, petitioner Joseph M. Kawal2 also worked part-
time for Jimmy Messenger Service, Inc. (JMS), a delivery service
owned and operated at all relevant times by Mr. Jimmy Mahabir,
a.k.a. Malcolm Mahabir (Mr. Mahabir), for which petitioner had
begun working in 1990 at a time when he was an unemployed,
illegal alien. During 1992, petitioner worked for JMS 2 to 2-1/2
hours during the evenings, 5 evenings a week, took no vacations
and no holidays, and earned $175 a week from JMS (JMS compensa-
tion).
During 1992, petitioners maintained a checking account at
Manufacturers Hanover Bank (checking account), which was in the
name of petitioner and to which petitioners had sole access.
During that year, petitioners made deposits into the checking
account that totaled $45,906 (bank deposits). During 1992,
petitioners did not usually deposit into the checking account any
2 Hereinafter, references to petitioner in the singular are to
petitioner Joseph M. Kawal.
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