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Petitioner worked for a one hour photo developing store
(photo store) in 1993 and 1994. In 1993 and 1994, she received a
salary of $250 per week or $13,000 per year in cash from the
photo store. Her employer did not withhold any tax from her
salary. Petitioner deposited some of her salary in her bank
accounts. She did not report her photo store salary in income
for 1993 or 1994.
Petitioner gambled in Atlantic City, New Jersey, almost
every weekend in 1993 and every other weekend in 1994. She
deposited some of her winnings in her bank accounts. She won a
$20,046 jackpot at a casino in Atlantic City in 1994.
B. Petitioner’s Bank Transactions
Petitioner deposited $38,865 in her bank accounts in 1993
and $43,764.47 in 1994. Those amounts include transfers from her
Chemical Bank savings account to her Chemical Bank checking
account of $1,000 in 1993 and $820 in 1994.
The following chart summarizes petitioner’s bank deposits
and withdrawals of $1,000 or more (hereinafter referred to as
large deposits or large withdrawals) from her Citibank checking,
Citibank savings, and Chemical Bank checking accounts in 1993 and
1994:
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Last modified: May 25, 2011