- 4 -
however, petitioner was the sole owner of this second account.
The first foreign account was closed in November 1986.4
During the years at issue, petitioner made 66 deposits to
the foreign account. Many intra-account transfers were also
made. The aggregate annual deposits to the foreign account were
as follows:
Year Number of Deposits Amount Deposited
1980 6 $202,000
1981 15 42,031
1982 17 52,016
1983 10 24,205
1984 5 17,695
1985 12 51,484
1986 1 1,096
More specifically, individual deposits to the foreign account
were as follows:5
Taxable Year 1980
Date Deposits
2/12/80 $ 20,000.00
6/4/80 10,000.00
6/23/80 80,000.00
6/30/80 12,000.00
7/14/80 70,000.00
11/24/80 10,000.00
total $202,000.00
4Throughout the remainder of this opinion, no distinction is
made between these two foreign accounts.
5Some pages of the account records are partially illegible,
and asterisks are used where figures could not be determined.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011