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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact and the exhibits attached thereto are
incorporated herein. Joseph Abraham and Margaret Abraham are
husband and wife. At the time when the petitions were filed in
these cases all of petitioners resided in El Paso, Texas.
Joseph Abraham (Abraham) was an attorney at law who
practiced and maintained his law offices in El Paso, Texas.
Miriam Lawrence (Lawrence) was his executive secretary and office
manager. She had been employed by him from July of 1969 until
February of 1993. During the years 1986 and 1987, Lawrence was
also engaged in a real estate business and some form of home-
based clothing and jewelry sales business.
Revenue Agent Alfonso Red (Agent Red), conducted an
examination of the Abrahams' 1987 joint Federal income tax
return. He also examined Lawrence's 1986 and 1987 Federal income
tax returns. In the course of his examinations, among other
things, Agent Red reviewed bank statements relating to numerous
bank accounts maintained by Abraham and bank statements and
canceled checks of several bank accounts maintained by Lawrence.
He discovered that substantial funds were being withdrawn from
bank accounts maintained by Abraham and deposited into bank
accounts maintained by Lawrence, and vice versa.
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