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he had a January 1, 1994, cash hoard of $180,000.29 At trial, he
29 On cross-examination, Michael testified as follows:
Q [Canavello] Mr. Downing, is this a typewritten
statement that you provided to the revenue agent at the July
meeting in 1997? Not the handwritten part, just the typing
part.
A (Perusing documents.) Oh. Yes, it is.
Q Thank you. I’d like you to read this sentence right
here to me, please, at the beginning of this -- this little
paragraph here.
A “I did not use any of my savings until 1994.” That?
Q Yes. Thank you. And on the second page, would you
read for me, please -- would you read me the numbers -- this
part of it, please, from here to here?
A “Approximate 1974 through 1981 estimated savings,
40,000. Approximate between 1982 and 1987, estimated annual
savings, 15,600.”
Q Yes.
A “Times five years equals 78,000. Approximate 1988
through 1989 estimated savings while employed at Millican
[Milliken] & Michaels, 31,000. Sale of house in 1993 profit
approximately 31,000. Total of 180,000.”
Q So now these would be the items that you listed in
your statement that you just identified, this statement here
that you brought to that meeting, as being the amounts that
added up to what was in the cash box?
A Approximately. A rough estimate.
Q Thank you very much.
So then, when you prepared that statement, your
estimate of what was in the cash box as at the beginning of
1994 was $180,000?
A I was speculating -- or estimate.
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