Estate of Leon Spear, Deceased, Jeanette Spear, Harvey Spear and Robert Spear, Administrators, and Jeanette Spear - Page 10

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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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