James E. and Chung H. Peacock - Page 18

                                        -18-                                          
          1985, 1986, and 1987.  Petitioners contend that respondent's                
          determinations are arbitrary.  We disagree.                                 
               Day did not give respondent's agent a net worth statement as           
          requested.  Respondent's agent gathered evidence to compute                 
          petitioners' net worth.  He reviewed financial statements that              
          petitioner-husband gave to banks to obtain loans.  He learned               
          that petitioners paid $45,002 in cash for a motor home in January           
          1983, made a $100,000 cash downpayment on the Glenstone property            
          in April 1983, and made other large cash expenditures in 1983.              
          Respondent's agent concluded that petitioners paid the first two            
          large expenses from a cash hoard and the rest from their earnings           
          in 1983.  He concluded that petitioners had $140,000 in cash on             
          December 31, 1982, and that it came from the Tokyo Saunas.                  
               Petitioners contend that respondent's determination about              
          their income in 1983 is arbitrary because respondent determined             
          that their income with only two saunas operating was larger than            
          their income in later years with three saunas operating.  We                
          disagree that this makes respondent's determination arbitrary.              
          The only documentary evidence showing the number of employees               
          petitioners had are the daily sheets that were not burned.  They            
          show that petitioners had 10 employees who worked 35 days in 1983           
          and 8 employees who worked 28 days in 1987.  The number of                  
          employees at each sauna appears to have varied from one to five             
          during the years in issue.  The record does not show how many               
          employees worked at each sauna in each year in issue.  Thus, the            




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