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53, or 80 percent, were for less than $5,000; 34 were for less
than $3,000. Additionally, most deposits consisted of multiple
checks. This means that the denominations of the checks used to
make the deposits were less than the amounts indicated in the
account records as being the total amount of each transaction.8
Petitioner has not attempted to explain this peculiar pattern of
predominantly small deposits. While it is conceivable that
petitioner deposited the proceeds that he allegedly received from
the real estate transactions into some unidentified account, and
then periodically deposited checks drawn against that account
into the foreign account, we hesitate to reach this conclusion
because petitioner has neither argued nor proved it. It is
equally conceivable that the deposits at issue were made using a
source of funds wholly unrelated to the transactions petitioner
cites. All that is certain is that (1) several real estate
transactions occurred during the years at issue, and (2) 66
predominantly small deposits were made throughout the course of
the 7-year period before the Court. Nothing in the record,
however, other than petitioner's self-serving testimony, links
these facts. While the exhibits petitioner relies upon may in
fact indicate his financial ability to make the deposits at
issue, they do not indicate, or even remotely suggest, that such
8For example, the account records indicate that 17 deposits
made in 1982 consisted of 35 separate checks.
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