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Petitioners’ Bank Accounts
At least during 1994 and 1995, petitioners owned and main-
tained several bank accounts at Community Bank and Trust (Commu-
nity Bank).
On October 13, 1995, Mr. Barmes completed five separate
applications (account applications) in order to open five sepa-
rate accounts with Community Bank, into each of which he made an
initial cash deposit of $1,000. Each account application re-
quired Mr. Barmes to provide the name and the taxpayer identifi-
cation number (TIN) of the account owner. Mr. Barmes provided
the following names and TIN’s in the respective account applica-
tions that he completed: (1) Sandbar Wholesale Trust--Barbara
[sic] Gift Shop, TIN 52-9876145; (2) Sandbar Family Trust, TIN
52-9876111; (3) Sandbar Wholesale Trust--Barmes Wholesale, TIN
52-9876145; (4) Sandbar Wholesales [sic] Trust--Payroll, TIN 52-
9876140; and (5) Sandbar Real Estate Trust, TIN 52-9876125.
Respondent did not issue TIN’s 52-9876145 and 52-9876125.
As of the date of the trial in this case, respondent had not
issued employer identification numbers (EIN’s) to Sandbar Whole-
sale Trust or Sandbar Real Estate Trust.
In completing the five separate account applications, Mr.
Barmes provided certain other information to Community Bank with
respect to each account. In each account application, Mr. Barmes
indicated that he was opening the account for a personal purpose
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