James E. and Chung H. Peacock - Page 13

                                        -13-                                          
               As discussed in par. B-3-e of the opinion, we find that                
          petitioners had $279,000 in cash on hand and a net worth of                 
          $622,478 on December 31, 1982.                                              
               4.   The Glenstone and Valley Road Properties                          
               Petitioner-husband obtained powers of attorney from Kiye               
          Oglesby and Ki Chong Kim dated October 11, 1982, to deal with the           
          property at 3600 Glenstone Avenue, Springfield, Missouri (the               
          Glenstone property) on their behalf.  On April 1, 1983,                     
          petitioner-husband contracted with Ed O. Day to buy the Glenstone           
          property for $325,000.  Petitioner-husband paid Ed O. Day                   
          $100,000 in cash as a downpayment on the property.                          
               On May 25, 1983, petitioners agreed to buy property at 1541            
          Valley Water Mill Road (the Valley Road property), adjacent to              
          the Glenstone property, for $80,000.  Of that amount, $70,000 was           
          due on August 1, 1983.                                                      
               On May 26, 1983, the Glenstone property transaction closed             
          and petitioner-husband gave Ed O. Day $134,000 in cashier's                 
          checks and a $90,000 note.  Twelve of the 13 cashier's checks he            
          gave Ed O. Day were in amounts less than $10,000.  Ki Chong Kim             
          was listed as the buyer of two of the cashier's checks that                 
          petitioner-husband bought.                                                  
               The record owners of the Glenstone property were                       
          petitioners, Kiye Oglesby, and Ki Chong Kim.  Neither Kiye                  
          Oglesby nor Ki Chong Kim knew that title to the Glenstone                   
          property was in their name.  On September 12, 1983, petitioner-             




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