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because they distrusted banks; however, they used banks
extensively. Id. at 39.
Giving appropriate weight to the finding of the Court of
Appeals that petitioner’s testimony relating to the cash hoard
was quite straightforward and appeared to be credible, 41 F.3d at
114, and the entire record, we conclude that petitioners used a
considerable amount of cash throughout the years before 1975 to
operate their business, and that they had a significant amount of
cash on hand on December 31, 1974. We think the parking lots and
petitioners' other businesses provided a likely source of a
significant amount of cash on hand on December 31, 1974. Based
on the foregoing discussion, and the entire record, we find
that petitioners had $200,000 cash on hand on December 31, 1974.
However, the lack of records showing the amount of petitioners’
cash on hand, the evidence in the record suggesting that Abe
Spear was not wealthy, the fact that Abe Spear chose one of Leon
Spear's brothers to be the executor of his will, and the fact
that Leon Spear contested his father's will lead us to conclude
that petitioners did not receive $380,000 in cash from Abe Spear
in 1957.
Petitioners argue that some of the money they received from
their corporations during the years at issue are repayments of
loans they made to the corporations before the years at issue.
Petitioner testified in her deposition in this case that the
loans existed; however, she testified in an earlier deposition in
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