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Petitioner explained only $14,230.89 of the $133,523.32 that
petitioner and Maxine disbursed from Barnett money market in
1986. The $14,230.89 represents expenditures for accounting
services for Ben's enterprises or for the racing boat
enterprises. The source of another $30,204.45 is undisputed: a
refund check from the IRS.
Table 9 reconstructs the bank deposits for 1986 and
summarizes the various explanations; as set forth therein,
petitioner had net unexplained bank deposits of $99,077.39 for
1986. Table 10, using income and deductions stipulated by the
parties, or calculated in respondent's notice of deficiency for
1986 and 1987, calculates petitioner's taxable income for 1986.
In 1987, the Safra account was inactive and closed in July
of that year. No deposits were made other than one for $400 to
correct an overdraft.
During 1987, Barnett money market continued to be active.
However, only $4,175 was deposited into the account, while
petitioner spent $12,650.93 supporting Ben's enterprises. Since
the expenditures tend to explain the deposits, only $4,175 is
credited to explaining 1987 deposits. The balance is applied to
explaining their source: the 1986 deposits. Petitioner's
disbursements from this account paid Apache Power Boat's building
rental and $4,850.93 for property taxes for Ben's property.
Funds also went to Allsworth's trust account.
Respondent conceded a $150,000 loan from petitioner's
sister-in-law used to post petitioner's bail. This corresponds
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