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of Tahiti for $1.1 million (Tahiti Property). On the Tahiti
Property during the years in issue, petitioners or others paid by
petitioners remodeled and renovated a house, installed a solar
water heating system, a spa, a culinary water system, and
underground utilities, dredged a boat channel, added a satellite
TV system, converted the electrical power system to 110 volts,
installed a diesel power generator as an alternate source of
electricity, and made many other significant improvements.
Petitioner personally designed and worked on many of the
projects undertaken at the Tahiti Property. Petitioner hired an
individual to provide security for the property and to manage and
pay repairmen and workmen hired to work on the property.
Generally, twice a year, petitioners traveled from
California or Utah to the Tahiti Property. Typically, on each
trip, petitioners would stay at the Tahiti Property for a number
of weeks.
To pay for costs incurred on the Tahiti Property in
connection with the various repair and improvement projects,
petitioners frequently transferred funds in U.S. currency from
their bank in California to a bank account they maintained in
Tahiti. Petitioners have documentation of total funds
transferred to their bank account in Tahiti to pay for expenses
relating to the Tahiti Property, but the evidence does not show
or substantiate the specific use of the funds transferred to
petitioners' bank account in Tahiti.
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