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portions of their drug proceeds into them. The
petitioners' neighbors, Mr. and Mrs. Peter Boyle, held
$117,000.00 for the taxpayers in a safety deposit box
which was opened in 1991. Dennis J. Deneault's mother
held approximately $25,000.00 in a safety deposit box
for the petitioners which was opened in 1991.
15. The safety deposit boxes were opened by the
petitioners in 1991. Keys to the safety deposit boxes
were held only by the petitioners. The nominees knew
that they were holding the money for the petitioners,
and were not permitted to withdraw any portion of the
money.
16. When their Internal Revenue Service audit
began, the petitioners continued to attempt to conceal
assets from the Service. Upon receiving notice by
letter of the examination of their 1991 income tax
return, the petitioners inquired of acquaintances as to
how to hide assets from the Internal Revenue Service.
They were told to place assets into an irrevocable
trust, and actually took steps to complete such an
instrument.
17. The petitioners have made implausible or
inconsistent explanations of their conduct during 1991.
They have made statements denying the existence of any
safety deposit boxes to which they had access during
1991. These are implausible statements, in light of
the fact that they opened the safety boxes and were the
only parties with keys to the boxes. The petitioners'
explanations have been inconsistent with their
behavior, such as their inquiring of acquaintances as
to how to hide assets from the Internal Revenue
Service.
18. Petitioners fraudulently understated their
taxable income during the 1993[4] taxable year in the
amount of $182,752, with the intent to evade the
payment of taxes on such income.
19. All of the underpayment of tax required to be
shown on petitioners' joint 1991 Federal income tax
return is due to fraud.
4 At the hearing on this matter, respondent's counsel
stated that the reference to "1993" in par. 18 of the Answer to
Amended Petition is a typographical error and should be "1991".
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