Ali Motaghayer - Page 5




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          amount, fifteen cash deposits totaling $32,580 (the cash                    
          deposits) were made as follows:                                             
               Date of Deposit               Amount                                   
               Jan.  6                       $3,635                                   
               Jan. 17                       5,340                                    
               Jan. 18                       8,700                                    
               Jan. 23                       4,000                                    
               Feb.  1                       350                                      
               Feb.  7                       1,000                                    
               Mar.  7                       1,000                                    
               Mar.  7                       400                                      
               May   5                       1,785                                    
               June  6                       100                                      
               June 22                       800                                      
               July 17                       120                                      
               Nov. 20                       1,700                                    
               Dec. 13                       150                                      
               Dec. 19                       3,500                                    
               Petitioner kept a check register for the checking account.             
          For the most part, entries into the check register are in                   
          English, although some entries also contain notations made in               
          Farsi.  With the exception of the $100 deposit made on June 6,              
          all of the deposits listed above are recorded in the check                  
          register.  Some of the deposit entries contain notations made in            
          Farsi.                                                                      
               On his 1995 Federal income tax return, petitioner reported             
          adjusted gross income of $34,083, which includes:  (1) Dividend             
          income of $55; (2) a short-term capital gain of $42,579 from the            





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