James E. and Chung H. Peacock - Page 12

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          thousand dollars on a motor home loan with a 17-percent interest            
          rate.                                                                       
               From 1978 to 1982, petitioners (a) bought four properties              
          for a total of $372,252, financing $255,7002 of that amount; (b)            
          spent $163,518 on insurance, mortgage payments, licensing fees,             
          taxes, and other items, which they deducted on their tax returns;           
          and (c) provided some support for family members, including Suil            
          Peacock and his family, Song Lee, Kil Lee, K.C. Urbon, and Il Nam           
          Lee.  Petitioners reported that their adjusted gross income for             
          that period was $264,799.                                                   
               From 1978 to 1982, petitioners did not receive any gifts or            
          inheritances that had significant value.                                    
               In early 1983, petitioners had outstanding loans from                  
          Northwest Federal, Puget Sound National Bank, and First                     
          Interstate Bank of Washington.                                              
               3.   Petitioners' Cash Hoard                                           
               Many people saw petitioners with large amounts of cash from            
          1978 to 1982.  None of them counted all of the cash.  In 1978,              
          Michael Koon, petitioner-wife's nephew-in-law, counted about                
          $100,000 of petitioners’ cash.  A large amount of other cash was            
          present that he did not count.                                              
               Petitioners buried some cash in a 5-gallon bucket under a              
          cement walkway in their backyard in 1979, and dug it up in 1981.            

               2 The parties agree that the amount financed was $246,994.             
          However, the record shows that the amount financed was $255,700.            




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