John R. Boone, Jr. - Page 22

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          earned or possessed, by petitioner's father, nor does it connect            
          petitioner to any of the activities of his father or show that              
          petitioner appropriated money from him.  Accordingly, we hold               
          that Exhibit T is irrelevant to the issue of a likely source of             
          income for petitioner, and is inadmissible.                                 
               Exhibit AD is a memorandum prepared by Gwen Leftwitch,                 
          respondent's special agent, of a conversation she had with Dick             
          Ripley, DEA special agent, dated June 6, 1995.  Neither were                
          called to testify in support of the memorandum, which is                    
          therefore inadmissible as hearsay.  Fed. R. Evid. 801(c).                   
               Exhibit AB consists of a compilation of computer printouts             
          and photocopies of 6 newspaper articles pertaining to the                   
          criminal organization to which John R. Boone, Sr., belonged,                
          referred to colloquially therein as the "Cornbread Mafia".                  
          Respondent offered no witness to establish the truth of the                 
          matters stated in Exhibit AB, which we therefore hold to be                 
          inadmissible hearsay.  Fed. R. Evidence 801(c).                             
               We turn now to address the substantive issue of whether                
          respondent has proven a likely source of income for petitioner              
          for 1989 and 1990.  Respondent argues that petitioner expended              
          and deposited money having similar musty and mildewed                       
          characteristics to that spent by his father and that, as the                
          marijuana business is a cash business, the cash more probably               
          than not came from the same source.  Respondent's only basis for            






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