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Petitioner disbursed funds totaling $50,628.44 from Safra to
Allsworth on a regular basis throughout 1986, either into
Allsworth's trust account or to him personally. Some of these
payments supplemented the marina land purchase that Allsworth
made with funds that he received directly from LCP Associates.
Of the funds deposited into Safra during 1986, $200,000 came
from a loan from Safra Bank. Respondent made no adjustment with
respect to those funds in the notice of deficiency for 1986 and
1987. The funds were deposited into the account in July and
August. The loan covered the $93,582 overdraft on Safra that
existed at the end of June 1986. Disbursements made in June,
which total $206,500 and remain unexplained by the record, caused
the overdraft. The unexplained deposits for 1986, summarized in
Table 9, are decreased by the amount of the loan.
None of the 11 debits to the account in June 1986 was
smaller than $2,000 and all were for amounts rounded to the
nearest thousand or five hundred dollars. The largest debits
were for $50,000 (two checks for that amount), $30,000, and
$20,000 (two checks for that amount). By the end of 1986,
petitioner had disbursed all the funds that had been deposited
during December 1985-October 1986.
Based upon exhibits stipulated by both parties, the total
deposits into Safra during 1986 exceed by $75,200 the amount
reported on Schedule C in respondent's notice of deficiency for
1986 and 1987.
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