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of the income that petitioner received from Linden Lumber.
During that year, generally, the amounts of the deposits into the
checking account varied and the timing of those deposits was
neither consistent nor regular. To illustrate, the bank state-
ments for the checking account (bank statements) for September
and October 1992 showed the following deposits:
Date of Deposit Amount of Deposit
Sept. 11, 1992 $1,500.00
Sept. 15, 1992 1,750.00
Sept. 21, 1992 1,567.52
Oct. 1, 1992 1,076.28
Oct. 2, 1992 1,021.00
Oct. 13, 1992 1,130.66
Oct. 23, 1992 1,268.77
Oct. 28, 1992 838.84
When petitioner began working for JMS in 1990, pursuant to
an arrangement that Mr. Mahabir had with him (Mr. Mahabir's
arrangement), petitioner received checks from JMS (JMS checks) in
amounts that exceeded the amount of compensation to which he was
entitled for his part-time work there. Under that arrangement,
in 1990 and throughout the period during which petitioner did not
have a bank account, petitioner cashed the JMS checks at Linden
Lumber, retained an amount equal to his JMS compensation, and
used the balance (i.e., the excess of each JMS check over the
amount of petitioner's JMS compensation, which excess is herein-
after referred to as Mr. Mahabir's money) for the benefit of Mr.
Mahabir, his family, and/or certain of Mr. Mahabir's acquain-
tances by, inter alia, returning it to Mr. Mahabir and/or his
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