James E. and Chung H. Peacock - Page 21

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          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-              




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