James E. and Chung H. Peacock - Page 11

                                        -11-                                          
               Respondent did not include petitioners' personal living                
          expenses in the net worth calculation on which the notice of                
          deficiency was based.  During the years in issue, petitioners               
          gave gifts and support to Suil Peacock and his family, had a                
          live-in maid, took trips to Florida, and gambled.  Respondent did           
          not include those expenses in the net worth calculation.                    
               In the net worth calculation, respondent took into account             
          the fact that $4,000 was stolen from petitioners in 1983.                   
          Petitioners did not deduct a theft loss on their 1983 tax return.           
               2.   Petitioners' Pre-1983 Use of Banks and Other Financial            
                    History                                                           
               Petitioners borrowed $28,000 in 1977 and $13,630 in 1978               
          from the North Pacific Bank in Tacoma, Washington.  Petitioners             
          submitted a statement of joint financial condition with their               
          1978 loan application.  After adjustment to show actual cost and            
          accumulated depreciation and to correct for minor errors, it                
          states that petitioners had a net worth of about $70,640 on April           
          7, 1978.  Petitioners did not state that they had a cash hoard on           
          either the application they submitted for their 1977 loan or                
          their statement of joint financial condition.  In 1978,                     
          petitioners reported $410 of interest income from Great Northwest           
          Savings and Loans and North Pacific Bank, and $4,237 of interest            
          expense on loans from First Interstate Bank of Washington (home             
          mortgage), Great Northwest Savings and Loans, Rainier Bank, and             
          North Pacific Bank.  On April 7, 1978, petitioners owed several             





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