Paul Mifsud and Maria G. Mifsud - Page 17




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          daily individual guest checks after he completed the sales sheet            
          for the day.                                                                
               Mr. Slater decided to expand his examination to petitioners            
          individually and asked them to provide him with certain informa-            
          tion, including personal bank statements.  Mr. Slater conducted             
          an analysis under the bank deposits method with respect to                  
          petitioners' bank deposits for the years 1993 and 1994.  That               
          analysis showed that for each of the years 1993 and 1994 pe-                
          titioners had substantial deposits in excess of the income that             
          they reported in their return for each of those years.  Mr.                 
          Slater requested a meeting with petitioners and their return                
          preparer whom they had authorized to represent them with respect            
          to the examination by the IRS of their returns for 1993 and 1994.           
          At that meeting, Mr. Slater asked for the source of petitioners'            
          bank deposits.  Mr. Mifsud informed Mr. Slater at that meeting              
          that petitioners had a cash hoard from around 1980 when they                
          moved from Michigan to Florida.  Mr. Mifsud indicated at that               
          meeting that immediately prior to petitioners' move to Florida              
          they had $200,000 in cash and $11,000 in a bank in Detroit.  When           
          they moved to Florida they brought that cash with them and                  
          deposited into a Florida bank account the $11,000 that they had             
          kept in a Detroit Bank.  Mr. Mifsud further explained to Mr.                
          Slater that petitioners kept the cash hoard until the years under           
          examination by the IRS when, according to Mr. Mifsud, they                  





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