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Haven, New Jersey. Petitioners paid with a cashier’s check,
which was paid for with a check drawn on the Radtam lottery
account at Security Savings & Loan.6
During the taxable years in issue, petitioners made the
following expenditures:
Year Item Purchase Price
1990 Boston Whaler 1$15,850
1990 Chrysler Voyager 26,500
1991 U.S. Savings Bonds 315,000
Total 37,350
1Paid in cash.
2Paid in cash.
3These purchases were made with a personal check written on one of
petitioners’ personal accounts payable to “cash”.
On June 15, 1989, Mr. Bacon’s cousin, Tadeusz Ras, purchased
a residence. Of the total purchase price, $50,220 was paid in
cash. A check in the amount of $16,600 was also part of the
purchase money used to acquire the property. On June 15, 1989,
$16,600 was withdrawn from Radtam’s savings account at Chemical
Bank.7 On June 27, 1989, Tadeusz Ras executed a mortgage on his
residence in favor of Mrs. Bacon for $64,000.
Beginning on or before July 1989, petitioners prepared
monthly summary sheets on behalf of Radtam, which purportedly
listed total deposits into its bank accounts for the month,
breaking down the total by category such as food, sales tax,
6Account No. 23 856021 3.
7Account No. 600-871255.
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