- 27 -
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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