Paul Mifsud and Maria G. Mifsud - Page 18




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          started depositing some of the cash hoard into petitioners' bank            
          accounts because Ms. Mifsud was insisting that he do that in view           
          of a robbery that occurred at petitioners' house in 1979.                   
               Upon learning Mr. Mifsud's explanation of the amounts of               
          cash deposits that petitioners made during 1993 and 1994 in                 
          excess of the income that they reported in their returns for                
          those years, Mr. Slater asked Mr. Mifsud for any information that           
          could corroborate their position that they had a cash hoard.  In            
          response, petitioners gave Mr. Slater a copy of a newspaper                 
          article with respect to the robbery that took place in 1979 at              
          their house in Michigan as well as tax returns for years prior to           
          1993.  However, no other information or documentation was pro-              
          vided to Mr. Slater in an attempt to corroborate petitioners'               
          position that their unexplained bank deposits were attributable             
          to their claimed cash hoard.  Mr. Slater expanded his examination           
          of petitioners to include their taxable year 1992, and he con-              
          ducted an analysis under the bank deposits method of petitioners'           
          bank deposits for that year.                                                
               In addition to auditing petitioners and Paul & Joe, Inc.,              
          Mr. Slater also examined Ms. Mamo and Mr. Mamo who owned 40                 
          percent of Paul & Joe, Inc.  Mr. Slater did not find any sub-               
          stantial unexplained cash deposits by them during the years under           
          examination.                                                                







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