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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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