Armin Unger - Page 4




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          were deposited into these accounts.  Petitioner and his mother               
          maintained joint safe deposit boxes at Sun Bank from 1986 to 1989            
          and at California Federal Bank during 1990.  Petitioner also                 
          maintained safe deposit boxes in his own name at Huntington Bank             
          and National City Bank from 1986 to 1990.                                    
               Petitioner purchased 10 automobiles during the period                   
          November 1986 to December 1990.  At least one of the automobiles,            
          a 1990 Mazda, was purchased with cashier’s checks showing an                 
          individual other than petitioner as the remitter.  That                      
          individual did not consent to the use of her name in the                     
          transaction.  Petitioner maintained message, mobile phone, and               
          cellular phone service under three different assumed names.                  
               Petitioner’s sole income-generating activity was illegal                
          narcotic sales.  However, when interviewed by respondent’s agents            
          in 1991, petitioner stated that he had no sources of income and              
          that he was fully supported by his family.  Petitioner did not               
          keep records of his income-generating activities and used cash               
          frequently.  Consequently, respondent determined petitioner’s                
          income by using the “net worth method”.  In making the                       
          determination of petitioner’s opening net worth, respondent                  
          determined the total amount contained in petitioner’s bank                   
          accounts, the amount of other cash on hand, and other known                  
          assets.                                                                      








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