Estate of Leon Spear, Deceased, Jeanette Spear, Harvey Spear and Robert Spear, Administrators, and Jeanette Spear - Page 8

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          parking lot maintenance and improvements.  Petitioners began to             
          operate parking lots in 1956.  Estate of Spear v. Commissioner,             
          T.C. Memo. 1993-213 (slip op. at 5).  Petitioner’s husband sold             
          used cars before that.  Id.  Petitioner testified that her                  
          husband dealt extensively in cash in connection with the parking            
          lots.  We believe that petitioners accumulated cash from the                
          parking lot business and used it to conduct their business.                 
               Petitioner testified that she and her husband used cash from           
          the cash hoard for their parking lot business.  She said they               
          used a lot of the cash to develop and expand their parking lot at           
          8th and Race Streets.  She also said they used some of the cash             
          for the parking lot petitioners created after they bought and               
          demolished the Skipper Hotel and for the PennDOT lots that                  
          petitioners acquired in 1973.  Petitioner also testified that               
          they bought a few properties between 1957 and 1970.                         
               Petitioner had no written records of how she and her husband           
          used the cash.  She testified that she only took money from, and            
          never put money into, the cash hoard.  She said that she had no             
          idea how much of the cash was left at the beginning of 1975, but            
          she said there was some money left.  She testified that a rough             
          guess was that the corporation owed petitioners a "couple of                
          hundred thousand dollars" in 1975.  She said the cash hoard was             
          pretty well down by 1977.                                                   
               The Court of Appeals limited its discussion of the record              
          primarily to the facts bearing on the sanctions issue.  Estate of           



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