Paul Mifsud and Maria G. Mifsud - Page 31




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          able to recall the precise amount of the monthly mortgage loan              
          payment (i.e., $38.55) that was required with respect to the                
          first house that petitioners purchased in 1960.  We believe that            
          Mr. Mifsud's inability to remember the amount of petitioners'               
          alleged cash hoard that they deposited into their bank accounts             
          during each of the years at issue is attributable to the fact               
          that they did not make such deposits.                                       
               Another aspect of Mr. Mifsud's and Ms. Mifsud's testimony              
          that we found to be implausible and not credible relates to their           
          assertion at trial that they made bank deposits during the years            
          at issue from their cash hoard because of Ms. Mifsud's strong               
          fear that their house in Florida would be burglarized, which fear           
          was precipitated by the 1979 robbery at their house in Michigan.            
          Petitioners' testimony rings hollow.  If, in fact, Ms. Mifsud's             
          fear that petitioners' house in Florida would be burglarized were           
          as strong as petitioners testified, we cannot fathom why they               
          would have continued to keep large amounts of cash in their house           
          throughout the 1980's and the years at issue, as they contend               
          they did.                                                                   
               On the record before us, we find petitioners' contention               
          that the source of the bank deposits at issue during the years at           
          issue was their cash hoard to be implausible and inconsistent               
          with and/or not supported by objective evidence in the record.              







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