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Petitioner testified that the unreported bank deposits and
cash expenditures made during 1989 and 1990 stemmed from his
great-grandfather's gift. Petitioner said that his great-
grandfather gave him the money because Walker felt that he did
not have much longer to live. Petitioner testified that Walker
told him that he, petitioner, should use the money for "something
purposeful" in his life, such as when he married or purchased a
home. Petitioner claimed that Walker told him the money was
located in a desk in Walker's office, in a small building
situated approximately 100 yards from petitioner's home.
Petitioner claimed that Walker told him never to tell anyone
about the money.
Petitioner testified that the money was in a mostly red,
cylindrical metal canister with a slip-off lid, and that the
canister had some type of design on the outside of it about which
he could not be specific. He said that the canister was about 8
inches tall and 10 inches in diameter. Petitioner testified that
he found the canister lying in an unlocked drawer of a file
cabinet attached to a metal desk. Petitioner claimed that he did
not count the money because his great-grandfather told him not to
do so.
Petitioner testified that he observed nothing in the
canister other than currency of all denominations, which was not
arranged in a specific manner. He claimed that he never changed
the way the cash was situated in the canister after receiving it,
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