Beatrice DiPierro - Page 14




                                       - 14 -                                         

          Hawthorne account).  That statement shows a transfer into that              
          account from Hawthorne Savings and Loan Association account No.             
          10133739-2 (the second Hawthorne account) in the amount of $7,627           
          on August 23, 1993.  There is, however, no statement of account             
          activity in evidence with respect to the second Hawthorne                   
          account.  We cannot, therefore, place any confidence in the                 
          completeness of petitioner’s bank deposit analysis because we do            
          not have confidence that petitioner took into account all                   
          deposits to all of her bank accounts in 1993.  Also, petitioner             
          added as deposits into the first Hawthorne account amounts that             
          were withdrawals and not deposits.  Finally, petitioner failed to           
          take into account the NationsBank purchase.                                 
               Alternatively, petitioner argues that the Fortune Bank                 
          deposit is the proceeds of rental income.  Petitioner’s failure             
          to maintain adequate records of her rental activities gives us no           
          confidence in that claim.  Petitioner also argues that the                  
          Fortune Bank deposit was withdrawn (the Fortune Bank withdrawal),           
          in cash, on the same day, December 8, 1993, that it was made and            
          used the next day, December 9, 1993, with additional cash, to               
          make the NationsBank purchase.  However, petitioner's testimony             
          with regard to those transactions was unclear:  petitioner                  
          testified that she did not know what she did with the Fortune               
          Bank withdrawal and cannot remember why she made the NationsBank            
          purchase.                                                                   





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