Carl Dimichele and Eileen Dimichele - Page 22

             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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