purchase for a couple whose total wages for the year
were $26,000.
Petitioner knew of the fur coats that were
photographed but not confiscated by the DEA agents who
conducted the search of the DiMicheles' home. Petitioner
testified that the fur coats "were really old * * *
antiques, really." However, she provided nothing to
substantiate that testimony.
Petitioner knew of the jewelry found in her home by
the DEA agents, and she knew of the jewelry found by the
agents in safe deposit box No. 301640. According to
petitioners' valuation, all of the jewelry was worth
$111,167.50. On the other hand, the Government's appraiser
valued the jewelry at $192,104. Even if we accept
petitioners' valuation, it is difficult to reconcile a
jewelry collection valued at more than $110,000 with the
total income reported on the joint returns filed by
petitioner and her husband.
Petitioner's brief claims: "Any jewelry that she
possessed was either purchased during the earlier stages
of the marriage, received as gifts or inherited as
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