Carl Dimichele and Eileen Dimichele - Page 21

             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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