Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 22

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               The Michoff, Srs., made deposits into their Placer savings             
          account in the amounts of $6,200 and $4,600 which are in issue in           
          the 1989 and 1990 tax years, respectively.  These deposits do not           
          make up the total amount of deposits into this account in 1989              
          and 1990.  Some of these deposits were part of larger deposits.             
               The Michoff, Srs., made a payment on their Bank of America             
          Visa account in the amount of $4,472.64 on August 18, 1989.                 
               Respondent contends that the above deposits and expenditures           
          are from unreported income of the Michoff, Srs.  The Michoff,               
          Srs., contend that the amounts at issue came from the following             
          sources:  “insurance refund”, “cash reserve”, "gambling winnings            
          equal losses”, “withdrawn and replaced from accounts”, “cash                
          withdrawn and replaced”, “refund”, “repayment of loan to Michael            
          Michoff”, and “transfer from Golden Union #1".  The Michoff,                
          Srs., argue that Beverly Michoff had saved money over many years            
          and hid it from her husband because he had a gambling problem.              
          They contend that many of the deposits in issue came from this              
          cash reserve.  Beverly Michoff testified that at one time she had           
          almost $100,000 in cash in a can.  Petitioners argue that some of           
          the cash reserves came from a personal injury settlement of                 
          Michoff, Sr.  Beverly Michoff testified that around 1971 they               
          received approximately $60,000 in settlement of the back injuries           
          of Mr. Michoff, Sr.  No documentary evidence was presented                  
          regarding the personal injury settlement, and Beverly Michoff's             
          testimony in this regard was vague.  Beverly Michoff testified              

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