Elizabeth Lai - Page 4

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          Belle Vie bank accounts.  Petitioner also received tips from her            
          work at La Belle Vie during 1999, 2000, and 2001.                           
          Petitioner’s Banking and Investment Accounts                                
               During 1999, 2000, and 2001, petitioner maintained bank                
          accounts at both Key Bank and U.S. Bank.  She maintained two                
          checking accounts at Key Bank in her own name.  Petitioner                  
          maintained a checking account at U.S. Bank under “La Belle Vie”             
          and a money market account under “Elizabeth T. Lai Sole Prop La             
          Belle Vie”.  Petitioner used the Key Bank accounts as her                   
          personal accounts and the U.S. Bank accounts as her business                
               Petitioner deposited and withdrew money from her personal              
          accounts at Key Bank as follows:                                            
               Year     Cash Deposits   Total Deposits   Withdrawals                  
          1999      $85,590.88          $113,766.37    $116,275.50                    
               2000       63,300.00        94,096.74       95,728.48                  
               2001      112,800.00       151,145.22      135,502.02                  
          Petitioner’s withdrawals from her personal accounts at Key Bank             
          included payments for home and car loans, utilities, clothes, and           
          other personal expenditures.                                                
          Petitioner’s Purchase of a Cashier’s Check in 2000                          
               On September 29, 2000, petitioner used cash to purchase a              
          cashier’s check of $55,204 from U.S. Bank.  Petitioner did not              
          withdraw the $55,204 that she used to purchase the cashier’s                
          check from any of her personal or business accounts.  Petitioner            

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