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On June 27, 1991, Mrs. Pert paid $50,000 to the IRS for Mr.
Riffe's taxes. On July 2, 1991, respondent applied $28,976 of
the $50,000 payment to 1986 and $21,024 to 1989 ($50,000 total).
On November 5, 1991, Mrs. Pert transferred $50,000 from C&S
trust account No. 836150 to C&S ultima account No. 81203284.
On November 7, 1991, Mrs. Pert withdrew $199,628 from C&S
trust account No. 836150. On November 8, 1991, at the Florida
Bank of Commerce, Mrs. Pert used the $100,000 from C&S trust
account No. 836150 to buy a $100,000 certificate of deposit (CD
1766), and Mr. Pert bought certificate of deposit No. 2775 for
$43,072 (CD 2775). The same employee at Florida Bank of Commerce
opened both certificate of deposit accounts for Mr. and Mrs. Pert
on November 8, 1991.
On December 11, 1991, Mrs. Pert paid $20,000 to the IRS for
Mr. Riffe's taxes. On December 20, 1991, respondent applied
$15,000 of the $20,000 payment to 1986 and $5,000 to 1988.
When CD 1766 matured around May 12, 1992, Mrs. Pert used
$50,000 of the proceeds to open joint checking account No.
0302052577 at Citizens Bank of Clearwater. She used the other
$50,000 to buy joint certificate of deposit No. 0300033611 with
Mr. Pert at Citizens Bank of Clearwater.
On June 16, 1992, Mr. Pert withdrew $6,000 in cash from
joint checking account No. 0302052577. On June 17, petitioners
prematurely redeemed certificate of deposit No. 0300033611 in the
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