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In 1994, Mrs. Beck deposited approximately $11,691 into her
separate account, mostly in cash. In 1995, she made deposits of
approximately $54,616 into the separate account, mostly in cash.
The primary source of these deposits was income from the dental
practice. In 1994, Mrs. Beck made cash deposits totaling at
least $6,120 to petitioners’ joint account.
From 1977 through September 1995, Dr. Beck, either singly or
with his former wife, E. Roman Beck, owned or controlled the
ownership of more than 100 acres in Blanco Hills County Estate in
Bexar County, north of San Antonio, Texas (the Blanco property).
In a foreclosure sale on October 3, 1995, the Blanco property was
sold to an unrelated third party for $290,000. On October 15,
1995, Mrs. Beck purchased the Blanco property from the third
party, in exchange for a note in the principal amount of
$331,845, executed by Mrs. Beck and secured by a lien on the
Blanco property. Mrs. Beck used income from Dr. Beck’s dental
practice to purchase the Blanco property.
Petitioners’ Tax Returns
Dr. Beck filed no Federal income tax returns for taxable
years 1991 through 1994 until September 1, 1995.6 For each year
6 Dr. Beck was granted extensions to file Federal income tax
returns for each of the taxable years in issue and filed his
returns on the dates indicated below:
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