Ronnie F. Judy - Page 3

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            not reflect income he received from sales of crops and livestock                          
            as follows:                                                                               
            Source                       1989            1990                                         
            Orangeburg Stockyard           $14,237         $14,898                                    
            Weathers Farm Supply             2,146            -0-                                     
            Four Holes Farm                  -0-             6,800                                    
            Total                         16,383          21,698                                      
                  Petitioner’s tax returns for the years at issue were                                
            assigned to C. Kevin Cox (Cox), a special agent in the Criminal                           
            Investigation Division of the Internal Revenue Service (IRS).                             
            Cox interviewed petitioner in October 1992.                                               
                  In response to Cox’s questions about the source of funds for                        
            specific expenditures, petitioner gave the following explanation:                         
            He had borrowed what he needed from his father, Blease Judy                               
            (Mr. Judy).  Mr. Judy’s sister--petitioner’s aunt--Lillie Mae                             
            Ellis, had died in 1985, leaving Mr. Judy $183,000.  Mr. Judy had                         
            withdrawn the entire inheritance from various bank accounts in                            
            1985, and secreted the cash in an ammunition box that he kept                             
            under his bed in the house he shared with petitioner’s family.                            
            Mr. Judy had given petitioner permission to withdraw funds from                           
            the ammunition box for expenses with the understanding that                               
            petitioner would pay them back.  On numerous occasions,                                   
            petitioner had helped himself from the contents of the ammunition                         
            box, but was dilatory in repaying.  At some point Mr. Judy had                            
            discovered to his dismay how much of his inheritance had been                             

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