-9-
withdrew $1,988 from his checking account, and a week later he
deposited a third-party check payable to Gibson in the same
amount, along with $1,030 in cash.12
Between January 6 and November 3, petitioner made 19
deposits, totaling $41,613, in savings account #1. At least 13
of the deposits, totaling $35,024, were deposits of cash.13 Two
of the deposits were combination deposits.14 Petitioner made one
deposit each to savings accounts #3 and #4. On April 15,
petitioner deposited $6,000 in cash into savings account #3, and
on April 14, he deposited $3,050 in cash into savings account #4.
Petitioner received $150 of interest on his checking
account; $600 on savings account #1; $162 on savings account #3;
and $87 on savings account #4.
Petitioner closed savings accounts #3 and #4 on July 12,
1993, by withdrawing the balances, $16,302 and $8,623,
respectively. Petitioner closed savings account #1 on November
16, 1993, by withdrawing the balance of $40,544 and depositing it
into his checking account.
12 Six of the deposits were combination deposits.
13 It is unclear from the record whether the deposits made on
Jan. 28, Mar. 10, Sept. 8, Oct. 5, Oct. 12, and Nov. 3, in the
respective amounts of $854, $1000, $900, $800, $800, and $1,600,
were deposits of cash.
14 The deposit on May 25 for the total amount of $6,115 was a
deposit of $6,000 cash and a check for $115. The deposit on Aug.
24 for the total amount of $3,320 was a deposit of $3,300 cash
and a check for $20.
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