Ronnie F. Judy - Page 17

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            of * * * money that he had taken out of the box.  It was just                             
            every time we came up with a specific expenditure item that * * *                         
            [petitioner] had, he stated that the money came out of the                                
            ammunition box.”  At trial, under cross-examination petitioner                            
            testified that he removed a total of approximately $72,000 from                           
            the ammunition box in 1990.  Yet this figure is double the amount                         
            implied by the source and application of funds computations on                            
            which petitioner and respondent agree.  On brief petitioner                               
            reproduces the results of those computations as follows:                                  
                        reported income4         $42,229                                              
                        unreported income         21,698                                              
            reported expenses        100,590                                                          
                        Amount I borrowed                                                             
            from estate funds        -36,663                                                          
            If, as petitioner maintains, he borrowed money from his father’s                          
            inheritance with the understanding that he was obligated to repay                         
            it, presumably he would have kept track of how much debt he was                           
                  Petitioner questions the plausibility of respondent’s                               
            explanation for the amounts in controversy.  He asserts that,                             
            owing to severe crop damage caused by Hurricane Hugo in 1989, his                         

                  4 “Reported income” is a mischaracterization.  This amount                          
            corresponds to the total available funds reported.  See the                               
            schedule set forth in our Findings of Fact.                                               

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