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able to earn on their bank deposits. If there was a better rate
of interest accruing on certificates of deposits, Mr. Mifsud
transferred funds from one or more of petitioners' checking
accounts and/or savings accounts in order to buy such a certifi-
cate, even though he recognized that a certificate of deposit was
not as liquid an asset as a checking or other similar bank
account. At all relevant times, Mr. Mifsud was aware that he
could not redeem a certificate of deposit before maturity without
incurring a financial penalty, as compared to withdrawing funds
at any time from a checking account or similar bank account. Mr.
Mifsud was not aware of any U.S. bank that had failed and thereby
caused injury to its depositors.
At all relevant times, petitioners financed through loans
the purchases of their residences, businesses, and automotive
vehicles and paid interest on those loans. After petitioners
moved to Florida, they purchased on credit at least the following
automotive vehicles: a 1979 Datsun 240Z, a 1986 Ford Bronco, a
1988 Lincoln Town Car, a 1988 Cadillac Eldorado, a 1990 Lexus LS-
400, a 1983 Datsun 240Z, a 1992 Cadillac Seville, a 1992 Honda
Accord EX, and two 1995 Lincoln Town Cars.
Mr. Mifsud submitted a credit application to Ford Motor
Credit Company, dated July 16, 1993. That application showed,
inter alia, (1) gross monthly salary of $10,833, or $129,996
annually, from Spring Hill restaurant, and (2) income from two
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