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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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