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March 27, 1998, respondent assessed $13,750 in additional tax,
penalties, and interest against the Doyles.
Post-Tax-Court-Opinion Financial Transactions
On September 14, 1992, a deed was recorded transferring real
property owned by the Doyles to their son and his wife for $1.
On September 21, 1992, two checks drawn on the bank account of
“Lavina Maudice or Nancy B. Doyle,”5 PNB account No. 04130419
(the Lavina/petitioner bank account), in the amount of $5,000
were made payable to Bridget Fink and Andrew Fink, petitioner’s
daughter and son-in-law, respectively. On September 24, 1992, a
check drawn on a Parkvale Savings Bank account, No. 022061410,
held in the names of “Bridget or Andrew Fink”, was made payable
to the Dreyfus Family of Funds in the amount of $10,000.
On October 30, 1992, a Parkvale Savings Bank account No.
000033816 was opened in the names of “Michele or Denise Doyle”
(Michele/Denise Doyle bank account No. 1).6 The initial deposit
to the account was $2,450 in cash and a $500 check from the
Lavina/petitioner bank account.
On November 5, 1992, an account at PNC Savings Bank, account
No. 10749779, was opened in the names of “Denise Doyle or Michele
Doyle” (Michele/Denise Doyle bank account No. 2). The initial
5Lavina Maudice, now deceased, was petitioner’s aunt.
6Michele and Denise Doyle are petitioner’s daughters.
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