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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 Ras’ purchase, the sum of $16,600 was withdrawn from Radtam’s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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