James E. and Chung H. Peacock - Page 20

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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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