Harvey M. Pert, Transferee - Page 18

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                         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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