Dennis J. and Teresa Deneault - Page 4

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          on behalf of petitioners at the hearing, nor did petitioners file           
          a statement with the Court pursuant to Rule 50(c).3                         
          Facts Deemed Admitted                                                       
               By virtue of the Court's granting of respondent's motion               
          under Rule 37(c), petitioners are deemed to have admitted the               
          following facts:                                                            
                    1.   During 1991, the petitioners lived in Ft.                    
               Pierce, Florida.  They have three daughters:  Mandy,                   
               Crystal, and Sarah Deneault.                                           
                    2.   Dennis J. Deneault is a wire lather by trade,                
               and engaged in a wire lathing sole proprietorship                      
               during 1991.                                                           
                    3.   Teresa Deneault worked for Cale of Ft. Myers,                
               Inc., doing business as Kirby Auto during 1991, earning                
               $3,177.06 in wages.                                                    
                    4.   During 1991, Dennis J. Deneault was engaged                  
               in the illegal trafficking and sale of narcotics and,                  
               as such, made illegal unrecorded cash sales of                         
               narcotics.                                                             
                    5.   Petitioners realized substantial cash sums of                
               income generated from the illegal narcotic trafficking                 
               business, which substantial cash sums enabled                          
               petitioners to maintain a standard of living                           
               inconsistent with the income reported from all other                   
               legal sources on their joint 1991 Federal income tax                   
               return.  Petitioners also failed to report $9,725 of                   
               income which was prematurely withdrawn from an                         
               individual retirement account and placed in a joint                    
               savings account by the petitioners.  Neither the income                
               from marijuana sales nor the withdrawals from the IRA                  
               account were included on the petitioners' joint Federal                
               income tax return for the year 1991.                                   


               3   Petitioners were reminded of the applicability of Rule             
          50(c) in the Court's order dated May 20, 1997, and expressly that           
          they could submit a written statement in lieu of (or in addition            
          to) attendance at the hearing.                                              




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