Kamil F. and Nagwa Gowni - Page 17

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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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