Thomas L. and Laura L. Gordon - Page 11

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               Initially, respondent determined that petitioner received              
          money from the following sources:                                           
                         Case                     Amount                              
                         Leon                $10,000                                  
                         Montenegro               1,000                               
                         Martinez            15,000                                   
                         Ramos                    20,000                              
                         Lopez                    10,000                              
                                        Total    $56,000                              
          Respondent alleges that the testimony of Cortez, along with                 
          petitioners' bank records, establishes that petitioners                     
          underreported their income in 1986.                                         
               At trial, Cortez testified that petitioner received cash               
          from thefts of drug-tainted money during 1986, including the                
          following:  $10,000 of stolen cash from the Leon case, $15,000 of           
          stolen cash from the Martinez case, and $10,000 of stolen cash              
          from the Lopez case.  In reference to the Montenegro case, Cortez           
          testified that he did not recall whether petitioner kept any of             
          the stolen cash for himself.  Cortez stated that he received                
          $1,000 from petitioner and that petitioner, as the investigating            
          officer in the Montenegro case, would have determined the share             
          that the other officers would receive and that petitioner would             
          usually have kept the largest share for himself.  Cortez could              
          not place a dollar amount on any money received by petitioner               
          from the Ramos investigation.  Cortez testified that he received            
          two bundles of cash, totaling $20,000, and that petitioner                  
          received two bundles of cash.  His estimate that petitioner                 





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