Hien X. Pham - Page 3




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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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