Jack J. Kramer - Page 14

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            the money laundering scheme, Sam Gilbert Associates, Inc. (SGA),                              
            owned by Sam Gilbert, made payments to petitioner labeled "wages"                             
            on W-2 Forms and withheld taxes therefrom.14  In 1987, petitioner                             
            rendered services to Fort Apache, Inc., and received $17,000                                  
            wages, with taxes withheld.                                                                   
                  The Internal Revenue Service audited petitioner, first for                              
            1986 and 1987, and then for 1985.  During neither audit did                                   
            petitioner produce the books and records necessary to                                         
            substantiate items of income, gain, loss, or deduction.  However,                             
            some documentation was given to respondent during the audits.  On                             
            advice of counsel, petitioner did not cooperate with respondent                               
            during the audit for 1986 and 1987.  Because of the lack of                                   
            records and failure to cooperate by petitioner, respondent used                               
            the bank deposits method to determine petitioner's income for the                             
            3 years at issue.                                                                             
                  During these 3 years, petitioner operated three bank                                    
            accounts in his and Maxine's names:  Safra Bank joint checking                                
            account (hereinafter Safra), Barnett Bank Joint Money Market                                  
            Account (hereinafter Barnett money market), and Barnett Bank                                  
            joint checking account (hereinafter Barnett joint checking).                                  
            Safra was active beginning in December 1985, and closed in July                               
            1987.  The other two accounts remained open during the entire 3-                              
            year period.  Safra, and to a lesser extent Barnett money market,                             


            14The payroll checks from SGA, while not necessarily for                                      
            services rendered, did provide support for petitioner during                                  
            1983-86.                                                                                      


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