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FINDINGS OF FACT
Some of the facts are stipulated and are so found.
A. Petitioner
Petitioner resided in Orange, California, when he filed the
petition. He is a technician who repairs copy machines. He
operated a copy machine service business known as Copy Care
Technology in 1996 and 1997. He sometimes hired subcontractors
to repair copy machines.
B. Petitioner’s Bank Accounts
Petitioner made the following deposits in his bank accounts
in 1996 and 1997:
1996
Amount
Bank deposited
Wells Fargo $1,410.57
Wells Fargo (2) 135,805.44
Bank of America 56,956.71
Total 194,172.72
1997
Amount
Bank deposited
Wells Fargo $118,031.27
Bank of America 81,772.02
Total 199,803.29
C. Petitioner’s Income Tax Returns
Petitioner filed his 1996 income tax return on April 15,
1997. He obtained a 4-month extension of time to file his 1997
return until August 17, 1998. He filed his 1997 income tax
return on August 17, 1998. He included with each of his 1996 and
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