Paul Mifsud and Maria G. Mifsud - Page 28




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          deposited within four years, or by around 1987, all of the                  
          $200,000 in cash which Mr. Mifsud informed Mr. Slater petitioners           
          brought with them to Florida in 1980.  If the Court were to                 
          accept Mr. Mifsud's testimony as to when petitioners started                
          making bank deposits from their alleged cash hoard and the                  
          amounts and frequency of such deposits, such alleged cash hoard             
          would have been fully deposited into petitioners' bank accounts             
          well before 1992, the first year at issue, regardless whether it            
          is assumed that petitioners had $332,000 or $200,000 in cash when           
          they moved from Michigan to Florida in 1980.                                
               Another illustration of the implausibility, inconsistency,             
          and lack of credibility of Mr. Mifsud's testimony relates to his            
          claim at trial that he maintained a cash hoard because he was               
          distrustful of banks, a distrust, according to his testimony,               
          that he learned from his parents.  The record belies Mr. Mifsud's           
          claim that he was distrustful of banks.  At all relevant times,             
          petitioners maintained multiple bank accounts into which they               
          deposited in the aggregate large amounts of cash.  For example,             
          petitioners had $220,870.67 on deposit at Barnett Bank on De-               
          cember 31, 1991.  In addition, during 1992, 1993, and 1994, they            
          made bank deposits totaling $197,097.69, $204,944, and $288,841,            
          respectively.  Furthermore, at all relevant times, Mr. Mifsud was           
          knowledgeable about Federal deposit insurance, which protects               
          bank deposits of one person up to $100,000.  He also was knowl-             





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