- 18 -
July 22, 1992 4,000
July 31, 1992 3,000
Total $33,000
From June 16, 1992, to February 28, 1993, Mr. Pert withdrew
a total of $74,000 from Citizens Bank, Sun Bank, and Barnett
Bank.
On November 23, 1992, respondent issued the notice of
deficiency to Mr. Riffe's estate, including the determination for
the addition to tax for fraud.
During 1991, 1992, 1993, and 1994, petitioners opened more
than 20 bank accounts, most of which were closed within 6 months.
Some of those accounts were opened only for 2 days.
G. Petitioners' Purchase of 610 Sandy Hook Road
On March 23, 1992, Mrs. Pert distributed Lot 30, College
Hill, to herself as sole beneficiary of Mr. Riffe's estate. She
had a new house built on that property in 1992. On April 19,
1993, Mrs. Pert sold the house and land for $60,000. After
deducting selling expenses, Mrs. Pert received $56,942 from the
sale. On April 20, 1993, Mrs. Pert bought a cashier's check
payable to Secure Title in the amount of $53,018. She withdrew
$3,925 from the original proceeds.
On February 16, 1993, Mr. Pert's parents wired $59,866 to
his money market account.
On March 4, 1993, Mr. Pert paid the Ford Motor Credit Co.
judgment (see par. E-2, above) in full.
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