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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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