Catherine Rosenthal - Page 7

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          later became Republic National Bank.  In 1996, he withdrew the              
          unreported $90,000 from Republic National Bank.  There is no                
          direct evidence of what Louis did with the unreported $90,000.              
          He did, however, own a certificate of deposit (CD) issued by                
          Republic National Bank.  That bank advised Louis that, on                   
          February 2, 1997, it had renewed (for 6 months until maturity on            
          August 2, 1997) a CD with a balance of $91,213.  The Republic               
          National Bank CD bore a different account number (No. 095-                  
          9501672878) than the former Crossland Savings Bank IRA (No.                 
          4888752).                                                                   
               In the innocent spouse questionnaire attached to her request           
          for innocent spouse relief dated July 25, 1999, petitioner listed           
          both her and Louis’s bank accounts.  Next to her listing of                 
          Louis’s account at Republic National Bank she wrote the account             
          number and “($90,000)”.                                                     
          Louis’s Will                                                                
               Louis died testate, and, under the terms of his will,                  
          petitioner received: (1) the house, “all policies of insurance              
          relating thereto, and all of the contents thereof”; (2) all of              
          Louis’s “tangible personal property”, and (3) his “Home Savings             
          Bank Account No. 6537415082 and Crossland Savings Bank Account              
          No. 4888752" identified in the will as his “pension accounts”.              
          The Home Savings Bank account is not listed on Schedule B of                
          either the original or the amended 1996 return or on petitioner’s           






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