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any items that were listed on deposit tickets totaling $300 or
more that were deposited to the Mansours’ personal bank account
at SunTrust Bank (SunTrust) for that year. In determining the
Mansours’ income for 1998 and 1999, the IRS summonsed and
evaluated copies of the bank statements from, checks written for
$1,000 or more on, and any items that were listed on deposit
tickets totaling $300 or more that were deposited to the
Mansours’ personal bank account at SunTrust for those years.
During the examination of the Mansours’ bank records, the IRS
requested that the Mansours provide documentation and
explanations as to any nontaxable items that were deposited to
their personal bank accounts. The IRS received information about
Mina of Sanford’s shareholder loan account in response to those
requests.
The examination of the Mansours’ income tax returns for 1996
through 1999 and the evaluation and analysis of their bank
records and other information spanned 2 years and consumed more
than 300 hours of revenue agent time.
Results of the Examination of the Mansours’ Income Tax Returns
A. 1996
The IRS made the following determinations with respect to
the Mansours for 1996:
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