Michael J. Downing and Sandra M. Downing - Page 20

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               By November 1997, Klimkiewicz was no longer on the case,               
          having been succeeded by Mia Sylve.                                         
          H.   Bank Deposits                                                          
               Petitioners maintained four bank accounts in two separate              
          institutions; both petitioners were signatories on each of these            
          accounts.  Neither petitioner maintained a separate account                 
          (i.e., an account as to which that petitioner, but not the other            
          petitioner, was a signatory) during the years in issue.                     
               Table 5 shows petitioners’ aggregate deposits into each                
          account, by account number, in each year in issue.                          
                                       Table 5                                        
          Account                       1994                  21995                   

          1225725403                  $8,874                $5,787                    
          5101046656                   48,335               114,702                   
          16423248061                 8,207                    N/A                    
          5101023648                   64,936                95,409                   
             Total Deposits            130,352               215,898                  
          1 This account was closed in April 1994.                                    
          2 Of the total 1995 deposits in these listed accounts, $200,                
          $5,000, and $31,475, respectively, were in cash.                            
          The bank accounts listed in table 5 are hereinafter sometimes               
          referred to collectively as the listed accounts.                            
               All four of the listed accounts were checking accounts.  The           
          first and third of the listed accounts were in the Jefferson                
          Guaranty Bank; the second and fourth were in the Premier Bank.              
          The first and second of the listed accounts were business                   






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