Dwight L. McKenna and Beverly S. McKenna - Page 24

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            possession, he gave it to Ms. Davis.  Despite three separate                                
            requests for investment accounts, Ms. Davis discovered one of the                           
            investment accounts herself when she was reviewing certain                                  
            canceled checks.  On one of these checks, she saw the name                                  
            "Shearson Lehman".  When asked about the investment accounts, Mr.                           
            Bruno told her there was an investment account with Shearson.  He                           
            further stated that he believed all of the money in the Shearson                            
            account represented transfers from petitioner's checking account.                           
            This categorization of the Shearson deposits as transfers from                              
            the checking account was significant because, if accurate, they                             
            would have represented nontaxable income already considered as                              
            income by Ms. Davis in her review of the account.                                           
                  Petitioners' 1987 income tax return did show interest                                 
            received from Shearson.  Ms. Davis did not receive an IRP                                   
            document, which is a document internally processed by the Service                           
            and lists interest income, capital gains, et cetera, reported to                            
            the Service.  However, neither the interest amount reported on                              
            the return nor the IRP document would have provided or given                                
            access to the detailed statements.  Without these detailed                                  
            statements, Ms. Davis would not have been able to determine                                 
            whether income had been deposited or withdrawn from that account,                           
            and whether the interest income or capital gains were earned from                           
            moneys placed in the account 10 years before or during the same                             
            year.                                                                                       






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