Michael London - Page 53

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             first included the Carmel Credit Union account in 1980 with              
             a balance of $280.11.  Petitioners contend that their total              
             assets are understated by the amounts that were in the                   
             Carmel Credit Union account from 1976 through and including              
             1979.  A check register from that account shows a balance                
             in the account of $648 at the end of 1977, $727.25 at the                
             end of 1978, and $25,105 at the end of 1979.                             
             In the revised net worth statement attached hereto                       
             as Appendix B, we have adjusted respondent's net worth                   
             statement by including a balance of $10,009.24 in the                    
             Shawmut County Bank account for the years 1977 through                   
             1983; by including a balance of $8,168.06 in the Provident               
             Institute for Savings account for 1976 through 1978; and by              
             including the yearend balances shown by the check register               
             for the Carmel Credit Union account No. 17795 for 1977                   
             through 1979.  Appendix B demonstrates that, even if we                  
             accept petitioners' position that respondent's net worth                 
             statement is in error with respect to those balances,                    
             the errors have no effect on respondent's computation of                 
             petitioners' net worth or taxable income for 1983 and 1985.              

             Cash Hoard Obtained as Gifts From Mr. London's Mother                    
                  Finally, petitioners argue that respondent's net worth              
             statement is wrong because it fails to take into account a               








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