Kamil F. and Nagwa Gowni - Page 16

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          Examination of the Mansours’ Income Tax Returns for                         
          1996 through 1999                                                           
               The examination of the Mansours’ income tax return for 1996            
          began in June 1999 and expanded to include 1997, 1998, and 1999.            
          The Mansours executed a power of attorney in favor of Bradshaw              
          with respect to their income tax returns for 1996, 1997, and                
          1998.  During the examination of the Mansours’ income tax                   
          returns, the IRS made requests for copies of workpapers, the                
          income tax returns of their business entities, and bank                     
          statements.  The Mansours did not produce adequate records with             
          respect to those requests, however, so the IRS summonsed the                
          Mansours’ bank records in order to make an appropriate                      
          determination of their income for those years.                              
               In determining the Mansours’ income for 1996, the IRS                  
          summonsed and evaluated copies of the bank statements from, the             
          checks written for $500 or more on, and any items that were                 
          listed on deposit tickets totaling $500 or more that were                   
          deposited to the Mansours’ personal bank account at First Union             
          National Bank of Florida (First Union) for that year.  In                   
          determining the Mansours’ income for 1997, the IRS summonsed and            
          evaluated copies of the bank statements from, checks written for            
          $500 or more on, and any items that were listed on deposit                  
          tickets totaling $500 or more that were deposited to the                    
          Mansours’ personal bank account at First Union as well as the               
          bank statements from, checks written for $1,000 or more on, and             





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