William B. and Donna McDermott - Page 4

                                         -4-                                          
          July  3                 3,165                                               
          July  3                 1,000                                               
          July 25                   831                                               
          Aug.  2                 2,500                                               
          Aug. 18                 1,000                                               
          Aug. 28                 1,248                                               
          Oct.  5                   102                                               
          Nov.  6                   114                                               
          Nov. 16                   457                                               
          Nov. 17                   289                                               
          Nov. 22                   210                                               
          Nov. 29                   251                                               
          Dec.  1                 3,000                                               
          Dec. 14                 3,000                                               
          Dec. 18                 3,000                                               
          Dec. 18                   454                                               
          Dec. 29                   763                                               
          23,784                                                                      
          Petitioners had not included any of these deposits in their 1995            
          gross income.                                                               
               During this proceeding, respondent conceded error as to 17             
          of the deposits determined to be includable in petitioners’ 1995            
          gross income.  Respondent now asserts that only the following six           
          deposits are so includable:  The July 3 deposit of $3,165, the              
          July 25 deposit of $831, the August 2 deposit of $2,500, the                
          December 1 deposit of $3,000, the December 14 deposit of $3,000,            
          and the December 18 deposit of $3,000.  The $3,165 was a deposit            
          made in cash or by check.  The $831 was a deposit made in cash.             
          The $2,500 and the first $3,000 were deposits made by wire                  
          transfer from the Lorain, Ohio, bank account of Ms. McDermott’s             
          mother.  The second $3,000 was a deposit made by check.  The                
          third $3,000 was a deposit made by check, the drawer of which was           
          a bank located in the Bahamas.                                              





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