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(o) According to their federal income tax
return, during 1991 the petitioners incurred medical
expenses of $1,590, paid property taxes of $1,148.00,
and paid $4,319 in interest payments. Per the return,
they also incurred $20 in miscellaneous deductions.
All of these amounts were reflected on schedule A of
the 1991 joint Federal income tax return.
(p) Federal tax payments were made during
1991 totaling $2,744.
(q) According to the public records of St.
Lucie County, the petitioners paid $2,500 relating to a
seizure of property during 1991.
(r) During 1991, the petitioners placed
$117,000 into a safety deposit box in the name of a Mr.
and Mrs. Peter Boyle.
(s) The net change in the petitioners' joint
account balance at Riverside National Bank during 1991
was a plus $1,100.
12. Petitioners have no non-taxable sources of
funds or excludible receipts which would require
adjustments in respondent's source and application
method for determining petitioners' 1991 taxable
income, such as loans or inheritances.
13. The petitioners made misleading statements to
agents of the respondent during their investigations
relative to the asset acquisitions and illegal narcotic
trafficking transactions as engaged in by the
petitioners during the taxable year 1991. In an
interview with Internal Revenue Service Revenue Agent
John Halligan at an Internal Revenue Service office
occurring January 6, 1993, Mrs. Teresa Deneault told
Mr. Halligan that the information on the petitioners'
Federal income tax return for the year 1991 was
correct. When asked if the petitioners ever possessed
or had access to safe deposit boxes, Mrs. Deneault
responded in the negative, despite there being bank
records of the petitioners' leasing such boxes during
the year 1991. Mr. Dennis Deneault also answered
negatively to this question.
14. The petitioners attempted to conceal assets
by using nominees to hold their money. They rented
safety deposit boxes from banks, and placed substantial
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