Robert G. Bacon and Barbara Bacon - Page 14




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          issue.  On the basis of the record, we cannot conclude that an              
          adjustment to respondent’s bank deposit analysis is justified for           
          cash on hand.                                                               
               B.  Loan to Tadeusz Ras                                                
               Respondent increased petitioners’ 1989 unreported income               
          under the bank deposit analysis by $64,000 due to an alleged                
          transfer from Mrs. Bacon to Tadeusz Ras (Mr. Ras).  Petitioners             
          argue that the alleged transfer should be eliminated from the               
          bank deposit analysis, since no transfer ever took place.                   
               Mr. Ras is Mr. Bacon’s cousin and has been continuously                
          employed by Radtam since 1991.  When Mr. Ras started working for            
          Mr. Bacon in 1991, he was paid approximately $5 to $6 per hour.             
          Mr. Ras cared for Mr. Bacon’s grandmother before he was employed            
          by Radtam.                                                                  
               On June 15, 1989, Mr. Ras purchased a house.  According to             
          the settlement statement, Mr. Ras owed the seller $108,213 and              
          satisfied this obligation with $50,220 in cash and paid the                 
          remainder with a number of checks.  One of the checks used to               
          purchase the house was in the amount of $16,600.  On the day of             
          Mr. Ras’ purchase, the sum of $16,600 was withdrawn from Radtam’s           
          savings account at Chemical Bank.16  On June 27, 1989, Mr. Ras              
          executed a mortgage on his residence in favor of Mrs. Bacon in              
          the amount of $64,000.                                                      
               Mr. Ras testified that his grandmother, not Mrs. Bacon,                

               16Account No. 600-871255.                                              



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