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During these same years, petitioner's approximate living expenses
were as follows:
1988 1989 1990 1991
Rent $3,000 $3,000 $3,000 $3,000
Living expenses 12,000 12,000 24,000 24,000
Car purchase --- --- 10,000 ---
Total 15,000 15,000 37,000 27,000
Petitioner lived in an apartment in a commercial building owned
by his parents throughout the years in issue. Petitioner did not
own any real estate or stock. Petitioner did not have a gambling
habit, a drug or alcohol problem, or any expensive hobbies.
Petitioner did not make any charitable contributions or have any
significant investments or purchases.
Mr. Yoon had two bank accounts at California Korea Bank and
one account at Security Pacific Bank which had the following
total deposits:
Year Total Deposits
1988 $32,480.59
1989 37,386.09
1990 181,410.86
1991 981,619.50
Total 1,232,897.04
Petitioner had Mr. Richard Rose, an accountant, prepare a
summary of Mr. Yoon's bank accounts. The net amount of deposits
was determined after an analysis was made by Mr. Rose to
eliminate transfers between accounts, credit memos, transfers
from credit cards, and redeposited checks which would normally
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