Paul Mifsud and Maria G. Mifsud - Page 27




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          Mr. Mifsud also testified that around 1983 he began depositing              
          money from petitioners' alleged cash hoard into various bank                
          accounts in increments of $3,000 to $10,000 usually once a week             
          or every three weeks.  However, Mr. Mifsud told Mr. Slater during           
          the IRS' examination of Paul & Joe, Inc., and of petitioners that           
          petitioners began depositing their cash hoard during the years at           
          issue, and Ms. Mifsud testified that they began depositing their            
          cash hoard in 1992.  Moreover, the amounts of the various bank              
          deposits that petitioners made throughout the years at issue are            
          for the most part much smaller than the level of deposits that              
          Mr. Mifsud testified he made from his cash hoard during those               
          years (i.e., from $3,000 to $10,000).                                       
               Assuming arguendo that, starting in 1983, Mr. Mifsud made 17           
          deposits of $3,000 a year, a conservative assumption in light of            
          Mr. Mifsud's testimony that around 1983 petitioners began de-               
          positing cash in increments of $3,000 to $10,000 usually once a             
          week or every three weeks, petitioners would have deposited                 
          within six and a half years, or by around 1989 or 1990, all of              
          the $332,000 in cash that Mr. Mifsud claims petitioners brought             
          with them in 1980 when they moved from Michigan to Florida.                 
          Furthermore, under the same assumption, petitioners would have              


               6  (...continued)                                                      
          examination of petitioners that they brought $11,000 in bank                
          deposits when they moved to Florida from Michigan.                          




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