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America the following cashier’s checks payable to the payees
indicated:
Date Payee Amount
3/2/921 Macy’s California $3,000
3/3/92 Macy’s California 10,000
5/18/92 Macy’s California 14,000
6/30/92 Mr. Kroma2 20,000
7/20/92 Carvis Discount3 16,000
1The copy of the $3,000 cashier’s check payable to Macy’s California is
not totally legible, but it appears that the date in March 1992 appearing on
that check is 3/2/92.
2The record includes only a copy of the front of the purchaser’s copy of
the cashier’s check payable to Mr. Kroma. We are not satisfied from that copy
or from any other evidence in the record that that cashier’s check was ever
negotiated. Even if we were satisfied that that cashier’s check was negoti-
ated, we are not satisfied from that copy or from any other evidence in the
record that Mr. Kroma deposited and/or cashed the cashier’s check payable to
him, nor do we know from the record the date on which that check was negoti-
ated. For example, Mr. Kroma could have endorsed that cashier’s check to
petitioner, who in turn deposited and/or cashed it.
3The record includes only a copy of the front of the purchaser’s copy of
the cashier’s check payable to Carvis Discount. We are not satisfied from
that copy or from any other evidence in the record that that cashier’s check
was ever negotiated. Even if we were satisfied that that cashier’s check was
negotiated, we are not satisfied from that copy or from any other evidence in
the record that Carvis Discount deposited and/or cashed the cashier’s check
payable to it, nor do we know from the record the date on which that check was
negotiated. For example, Carvis Discount could have endorsed that cashier’s
check to petitioner, who in turn deposited and/or cashed it.
Petitioner’s Income-Producing Activities
As discussed in more detail below, during each of the years
at issue, petitioner operated one or more sole proprietorships
and engaged in certain income-producing activities with certain
individuals and entities. In addition, during part of 1993,
petitioner was a partner in a partnership operating under the
name MZ Trading Company (MZ Trading).
On January 1, 1991, January 1, 1992, and January 1, 1993,
petitioner and Ms. Brodsky did not have a cash hoard or other
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