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work if, as Mr. Mifsud testified, his father did not have to do
so because he brought approximately $500,000 with him to the
United States a year before he started working as a head waiter.
Nor do we believe that Mr. Mifsud's elderly and ill mother would
be living on Social Security benefits and gifts from her children
if, in fact, Mr. Mifsud's father had brought around half a
million dollars to the United States in 1951, which would have
belonged to her upon the death of Mr. Mifsud's father.
To illustrate further why we shall not accept and rely on
the testimony of Mr. Mifsud and Ms. Mifsud relating to petition-
ers' claim that the source of the bank deposits at issue was a
cash hoard which they brought with them when they moved from
Michigan to Florida, Mr. Mifsud testified that petitioners
brought $332,000 in cash and $69,000 in bank deposits to Florida
when they moved there in 1980. However, Ms. Mifsud testified
that petitioners had "over $200,000 cash" when they moved from
Michigan to Florida. Moreover, during the examination of Paul &
Joe, Inc., and of petitioners by the IRS, Mr. Mifsud told Mr.
Slater, the revenue agent responsible for that examination, that
the source of funds that petitioners deposited into their bank
accounts during the years at issue was $200,000 in cash, which
they brought with them when they moved from Michigan to Florida.6
6 Mr. Mifsud also told Mr. Slater during the IRS'
(continued...)
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