couple owned two cars, furs, $419,972 in cash, jewelry,
valued by petitioners at $111,167.50, and various
parcels of real estate.
During each of the years in issue, petitioner knew
that she and her husband had purchased the 1981 Lincoln
Continental for $16,200, that they had made a cash down-
payment of $6,200, and that they had borrowed the balance
of $10,000 from Fidelity Bank & and Trust Co. of New
Jersey. She knew that the car was titled in her name and
she had executed the Credit Application and the Purchased
Money Motor Vehicle Security Agreement submitted to the
lender, Fidelity Bank & Trust Co. of New Jersey. She also
knew or should have known that the cost of the 1981 Lincoln
was more than 58 percent of the total income reported on
petitioners' 1981 return.
Similarly, petitioner knew that her husband had
purchased a new Cadillac Eldorado in December 1983.
The record of this case does not include the purchase
documents for the Cadillac which cost $25,400. Never-
theless, petitioner knew or should have known that the
Cadillac Eldorado was a relatively expensive car to
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