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from that Fortune Bank account. Petitioner purchased a check
with cash at NationsBank (formerly NCNB National Bank) on
December 9, 1993, in the amount of $11,250 (the NationsBank
purchase).
Petitioner’s Returns
Petitioner did not prepare her own Federal income tax
returns for 1992 and 1993. She relied on her accountant.
Respondent’s Adjustments
Among the adjustments made by respondent to petitioner’s
1992 and 1993 gross income are additions in the amounts of
$25,000 and $21,250 for 1992 and 1993, respectively. In the
notice of deficiency, respondent explains those adjustments as
follows: “It is determined that during the taxable years 1992
and 1993, the cash of $25,000 and $21,250, respectively, that you
deposited in various banks was not reported on your income tax
returns.” Respondent identifies the cash deposits in question as
the NCNB deposit, the Fortune Bank deposit, and the NationsBank
purchase.
1(...continued)
$10,000 to petitioner’s account in Fortune Bank on Dec. 8, 1993,
and we so find.
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