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During the years in issue, Mr. Webber maintained a
bank account with First Interstate Bank under the name
Bill Webber d/b/a Bill's Business Service. He also
maintained two accounts with the Santa Cruz Community
Credit Union under the same name. Set forth below is a
summary of the aggregate deposits made into Mr. Webber's
three accounts, the amount of cash received at the time
the deposits were made, the gross receipts reported on
Mr. Webber's Schedules C, and the unreported income
determined by respondent:
Bank 1992 1993
First Interstate Bank $31,036.82 $24,995.26
Cash received 9,450.00 6,350.00
Santa Cruz Community Credit Union, #1 943.50 1,508.33
Santa Cruz Community Credit Union, #2 20,709.74 14,858.33
Aggregate deposits and cash received 62,140.06 47,711.92
Less gross receipts reported 31,546.00 28,039.00
Unreported income 30,594.06 19,672.92
On or about January 2, 1991, Mr. Webber caused a
declaration of trust to be executed entitled the Ghalardi
Income Tax Education Foundation "A Trust", herein referred
to as Ghalardi. Pursuant to the declaration of trust,
Ms. Lillian Girarde, the sister of Mr. Webber's
grandmother, purportedly created an irrevocable trust:
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