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 toPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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