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In April 1992, petitioner applied for a loan to refinance
the Belleair property. In her loan application, petitioner
represented that her net worth was $933,354.
Petitioner’s Bank Accounts
Petitioner owned the following bank accounts in 1992 and
1993:
Fortune Bank, account No. 002-9072131
NCNB National Bank, account No. 3502977933
NCNB National Bank, account No. 3506708708
NCNB National Bank, account No. 3510298128
NCNB National Bank, account No. 3706446642
Hawthorne Savings and Loan Assoc., account No. 10130059-8
Hawthorne Savings and Loan Assoc., account No. 10133739-2
During the course of respondent’s examination of
petitioner’s 1992 and 1993 returns, petitioner failed to provide
respondent complete information concerning those bank accounts.
Bank Transactions
Petitioner deposited $25,000 in cash into NCNB National
Bank, account No. 3502977933 on February 10, 1992 (the NCNB
deposit). Petitioner deposited $10,000 in cash into Fortune
Bank, account No. 002-9072131 on December 8, 1993 (the Fortune
Bank deposit).1 On that same date, petitioner withdrew $10,000
1 That $10,000 deposit is shown in Ex. 13-M, p. 13, the
Fortune Bank statement for account No. 002-9072131 for
Dec. 15, 1993. Ex. 5-E contains a true copy of Internal Revenue
Form 4789, Currency Transaction Report, filed by Fortune Bank,
which shows a $10,000 deposit on Dec. 8, 1993, to petitioner’s
account No. 0029064821. We cannot resolve that discrepancy. The
parties seem satisfied that there was only one cash deposit of
(continued...)
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