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travel by subway to her home carrying cash ranging from $350 to
$800. Mr. Margolis would then travel back to Manhattan on the
following Monday to deposit 95 to 100 percent of the cash to
petitioners' account at National Westminster Bank, also located
in the Empire State Building. Apparently petitioners' reason for
this practice was so that they would have cash available for
their weekend expenditures.
We have reviewed petitioners' bank account statements and
find that petitioners' testimony is not supported by their
banking pattern. For instance, a number of the deposits claimed
to be deposits of cashed checks are in the amount of $514.
However, upon review of the record, it appears that the $514
deposits are actually deposits of unemployment compensation
received by Mrs. Margolis. Respondent gave petitioners credit
for Mrs. Margolis' unemployment compensation in the bank deposits
analysis.
According to petitioners' 1992 return, Mrs. Margolis
received $13,621 in unemployment compensation during that year.
Based on the record, it appears that she received an initial 1
week payment of $257 ($514 � 2) on January 6, 1992 (supported on
the record by a deposit of $257 to petitioners' account on that
day) and 26 biweekly payments of $514, making a total of $13,621
for that year. Thus, the $514 deposits are in fact deposits of
unemployment compensation and not deposits of the proceeds of
Mrs. Margolis' cashed checks.
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