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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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