Donald J. and Lillian Joy Miravalle - Page 9

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          life savings, in a "lock box".  Petitioners bought and sold tax-            
          free municipal bonds through their account at Merrill Lynch,                
          investing approximately $10,000 in 1983, $60,000 in 1984, and               
          $40,000 in 1985.  In addition, during 1984, petitioners purchased           
          City of Brooksville bonds for $20,277.50 and New Jersey Economic            
          Development Authority bonds for $41,191.67 through Jay Milton               
          Newton, Inc.,  which they later transferred to their Merrill                
          Lynch account.                                                              
               Petitioners purchased a 56' sailboat on April 17, 1985, for            
          $125,000.  They purchased two warehouses on April 29, 1986, for             
          $372,000.  Petitioners paid for the sailboat and the warehouses             
          without the use of financing; their Merrill Lynch account served            
          as the conduit for the funds.  Petitioners sold nearly all of the           
          bonds in the Merrill Lynch account to help fund the purchase of             
          the warehouses on April 29, 1986.                                           
               Tax Returns and Audits                                                 
               Petitioners did not file income tax returns for the taxable            
          years 1979 through 1983.  Petitioners filed joint income tax                
          returns for 1984 through 1986, which they prepared themselves.              
          Attached to each of the 1984 through 1986 tax returns were                  
          Schedules C (Profit or (Loss) from Business or Profession),                 
          wherein petitioners reported income and expenses on the cash                
          method of accounting from the manufacture and sale of marine air            
          conditioners operating under the name of DJM Enterprises.  The              






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