-21- B. Opening Net Worth and Cash on Hand The parties agree about petitioners' opening net worth for the years in issue except for the amount of cash they had on hand on December 31, 1982, 1983, 1984, 1985, 1986, and 1987. Respondent contends that petitioners had a cash hoard of $140,000 on December 31, 1982. Petitioners contend that they had more than $660,000 in cash on that date ($250,000 from Wilma MacFarland, $150,000 from Tobey Peacock, $200,000 from black market sales and skimming from slot machines in Vietnam, and more than $60,000 from previously taxed income). We conclude that petitioners had much less than $660,000 in cash on hand on December 31, 1982, from the sources they claimed, but that they had more than respondent determined. As discussed above at par. A-2, and below at par. B-3-e, we conclude that petitioners had $279,000 in cash on hand on December 31, 1982, and $40,000 on December 31, 1983, 1984, 1985, 1986, and 1987. 1. Cash Hoard Sources Asserted by Petitioners a. Wilma MacFarland Petitioners claim that they received $250,000 in cash from Wilma MacFarland. Petitioners claim that the $250,000 includes a $125,000 loan that Wilma MacFarland made to petitioner-husband on July 30, 1979, with the understanding that the money would be repaid on demand without interest, but that any balance due when Wilma MacFarland died would be considered paid in full. Wilma MacFarland died a few months after July 30, 1979. Petitioner-Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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