Estate of Leon Spear, Deceased, Jeanette Spear, Harvey Spear and Robert Spear, Administrators, and Jeanette Spear - Page 7

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          reconsider whether petitioners had any cash on hand on                      
          December 31, 1974.                                                          
               Petitioner’s testimony gives two possible sources of                   
          petitioners’ cash on hand on December 31, 1974.  One is a cash              
          hoard from 1957; the other is their parking lot business they               
          have conducted since 1956.                                                  
               Petitioner testified in the deposition that she and her                
          husband had a large cash hoard.  She testified that one night in            
          1957 her husband came home with a bag of money which he said his            
          father, Abe Spear, had given to him.  Petitioner's husband's                
          father died soon thereafter.  She did not remember whether the              
          bag was bigger or smaller than a grocery bag.  She said that she            
          helped him count the money, but he did most of the counting.  She           
          testified that the next night he came home with a second bag of             
          money.  She said that, combined, both bags contained “[A]bout 360           
          or 380 or 3 something, that was it.”  She said that in less than            
          1 year they put some of the money in a safety deposit box.  She             
          said she did not remember how long the rest of the money was in             
          their house.                                                                
               Another possible source of petitioners’ cash on hand on                
          December 31, 1974, based on petitioner’s deposition, is                     
          petitioners’ parking lot and other businesses.  Petitioner                  
          testified in her deposition that her husband, Leon Spear,                   
          routinely handled cash and received cash from petitioners'                  
          parking lot business, and used cash to pay for expenses such as             



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