James E. and Chung H. Peacock - Page 22

                                        -22-                                          
          husband testified that he had not repaid any of the $125,000 when           
          she died.                                                                   
               There is no credible evidence that Wilma MacFarland had a              
          significant amount of money.  She had few assets when she and               
          MacFarland were divorced in 1973.  MacFarland was required by               
          court order to make support payments to her of $150 a month.  She           
          reported receiving less than $28,000 as wages or self-employment            
          income on her income tax returns during her life, and never more            
          than $3,600 in any year.  She did not report any wages or self-             
          employment income on her income tax returns for 1973 to 1979.  We           
          conclude that Wilma MacFarland was not the source of a                      
          significant amount of petitioners' cash hoard.                              
                    b.   Tobey Peacock                                                
               Petitioners claim that they received $150,000 in cash from             
          Tobey Peacock as follows:  (1) $70,000 in 1971, for Suil                    
          Peacock's education; (2) $50,000, which, right before Tobey                 
          Peacock died in 1973, he told petitioner-husband that he had                
          hidden on his farm and that he wanted petitioner-husband to have;           
          and (3) $30,000 at various times over the years.  Petitioners               
          point out that petitioner-husband was Tobey Peacock's only son.             
               There is no credible evidence in the record that Tobey                 
          Peacock had a significant amount of money.  Tobey Peacock                   
          reported less than $3,000 as wages or self-employment income on             
          his income tax returns during his life and never reported more              
          than $1,200 in any year.  We do not believe that he gave                    




Page:  Previous  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  Next

Last modified: May 25, 2011