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3. Whether Respondent Adequately Investigated Leads
Petitioners contend that respondent failed to investigate
adequately leads they provided relating to their cash on hand on
December 31, 1982. We disagree.
Petitioners point out that respondent did not investigate
whether petitioners' cement walkway had been relaid even though
petitioners told respondent that they had buried cash in their
backyard, built a cement walkway over it, and relaid the cement
after they broke it to get the cash. Petitioners argue that
respondent should have checked to see if the cement had been
relaid. We disagree. Respondent does not dispute that
petitioners buried cash in a 5-gallon bucket under the walkway in
1979 and dug it up in 1981, but verifying that the walkway had
been relaid would not show how much cash petitioners buried or
had on hand on December 31, 1982.
Petitioners argue that respondent did not sufficiently
interview witnesses who saw petitioners' cash. We disagree.
Respondent's agent attempted to determine how much cash
petitioners had. No witness counted more cash in petitioners'
possession than respondent determined petitioners had, and
respondent would have learned nothing definite by interviewing
witnesses who saw uncounted cash. Petitioners did not offer any
worthwhile leads which respondent failed to investigate. We
conclude that respondent did all that was required to check
leads.
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