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account. During the years at issue, petitioners maintained bank
accounts at Barnett Bank, Sun Bank, and Citizens Federal. During
1993 and 1994, petitioners also maintained a bank account at
Great Western Bank. During the years at issue, petitioners made
numerous deposits of cash into their bank accounts, which, for
the most part, were regularly made throughout the year in rela-
tively small amounts (i.e., around $1,000 or less). In 1993,
Great Western Bank issued a cash transaction report with respect
to petitioners because they made two cash deposits on August 20
of that year, which totaled in excess of $10,000.
During the years at issue, petitioners deposited the fol-
lowing aggregate amounts into their bank accounts at the banks
indicated:
1992 1993 1994
Barnett Bank $103,595.40 $118,519 $183,044
Great Western Bank -- 47,863 70,086
Sun Bank 19,691.10 7,610 12,221
Citizens Federal 73,811.19 30,952 23,490
Total Deposits 197,097.69 204,944 288,841
At all relevant times, Mr. Mifsud paid attention to the
economy and to changes in interest rates and how such changes
might affect petitioners. For example, when interest rates fell,
Mr. Mifsud contacted Barnett Bank in order to refinance petition-
ers' house at a lower interest rate. At all relevant times, Mr.
Mifsud also was concerned with the interest that petitioners were
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