Michael London - Page 51

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                  Natl. Grand Bank     9,580     5,100      --        --      --    --   --   --   --   --
                  Natl. Grand Bank     9,640     4,220      --        --      --    --   --   --   --   --
                  Marblehead Sav.   11,800         --            60        --         --         --     --     --    --    --
                            68,020     33,860  26,760   13,660 13,060  320    --    --   --   --

                       If we were to accept petitioners' assertion that               
             they maintained balances in the accounts at the five banks               
             in the amounts and for the years shown above, we would                   
             agree with their contention that respondent's net worth                  
             statement should have included those bank balances as                    
             assets.  It is unnecessary to make that finding, however,                
             because even if it were true, it would not change                        
             respondent's computation of petitioners' taxable income for              
             1983 and 1985.  The revised net worth statement attached                 
             hereto as Appendix B shows that inclusion of the above bank              
             balances as assets would not cause any change in                         
             respondent's computation of taxable income for 1983 and                  
             1985.                                                                    

             Incorrect Bank Balances                                                  
                  Petitioners also complain that the balances included                
             in respondent's net worth statement for accounts at                      
             three banks are wrong.  First, petitioners complain                      
             that respondent's net worth statement includes a balance of              
             $18,288.31 for petitioners' Shawmut County Bank account No.              
             685-94601, for the first time in 1984, whereas, in fact,                 








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