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Taxable Year 1986
Date Deposits
4/2/86 $1096.00
total $1096.00
The account records indicate that most of the 66 deposit
transactions involved the deposit of multiple checks.
During the years at issue, the foreign account earned the
following amounts of interest:
Year Interest Earned
1980 $ 7,503
1981 33,286
1982 33,594
1983 24,408
1984 30,539
1985 48,621
1986 36,886
In 1980, petitioner also realized a short-term capital gain in
the amount of $13,117.23 from assets contained in the foreign
account.
Petitioner used a professional accountant to prepare his tax
returns for each year at issue. He did not, however, provide the
accountant with information pertaining to the existence of the
foreign account. Consequently, the accountant did not include,
and petitioner did not report on his returns for any taxable year
at issue, either the interest earned on the foreign account or
the short-term capital gain realized in 1980.6 Petitioner
6Similarly, petitioner did not file a Form 90-22.1 (report
of foreign bank and financial account) with regard to the foreign
account for any taxable year at issue.
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