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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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