Paul Mifsud and Maria G. Mifsud - Page 30




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          return than the interest that they were earning on their checking           
          and/or savings bank accounts, and refinance the mortgage loan on            
          their house when interest rates fell below the interest rate                
          applicable to that loan, would not forgo the ability to earn                
          interest income on petitioners' alleged cash hoard of $332,000              
          (or even $200,000), especially considering the high interest                
          rates available during the 1980's, which peaked at 20 percent in            
          1982.  Considering those high interest rates, petitioners would             
          have forgone interest income of as much as $60,000 a year by                
          keeping the alleged cash hoard of $332,000 at home and not                  
          depositing it into banks.  That amount of forgone interest income           
          is more than petitioners reported as total income for any of the            
          years 1986 through 1991.  We do not believe that petitioners                
          would have forgone such interest income, and we do not believe              
          that they did.  That is because we do not find credible their               
          claim that their cash hoard of $332,000 (or $200,000) was the               
          source of the bank deposits at issue.                                       
               It is also significant that Mr. Mifsud testified at trial              
          that he could not recall the amount of petitioners' alleged cash            
          hoard that they deposited into their bank accounts during each of           
          the years at issue.  We find Mr. Mifsud's claimed inability to              
          remember those alleged matters to be suspect in view of his                 
          ability to remember with specificity other facts relating to                
          petitioners' financial situation.  For example, Mr. Mifsud was              





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