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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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