Lawrence J. Polidori - Page 3

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits are incorporated             
          herein.  At the time the petition was filed, petitioner resided             
          in Ozona, Florida.                                                          
               Petitioner and his former spouse2 were husband and wife                
          throughout the years at issue.  They filed joint Federal                    
          individual income tax returns for taxable years 1980, 1981, 1982,           
          1983, 1984, and 1985.  Despite being married, petitioner filed              
          his 1986 Federal individual income tax return using the filing              
          status of "head of household."                                              
               Petitioner was a practicing dentist throughout the years at            
          issue.  During that period, both he and his former spouse were              
          co-owners of a foreign bank account (the foreign account) located           
          in the Bahamas.  From time to time, petitioner opened subsidiary            
          accounts within the foreign account for various investment                  
          purposes.  Neither petitioner nor his former spouse made                    
          withdrawals from the foreign account prior to 1986.3  On                    
          September 1986, petitioner opened a second foreign account with             
          the same Bahamian bank.  Unlike the first foreign account,                  



               2Petitioner's former spouse, Fern M. Polidori, is not a                
          party in this case.                                                         
               3The parties have stipulated that neither petitioner nor his           
          former spouse withdrew funds from the foreign account prior to              
          1986.  The account records, however, indicate that at least one             
          cash withdrawal was made on September 29, 1981, in the amount of            
          $300.                                                                       


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