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petitioners money, especially considering that he disapproved of
their lifestyle. We conclude that Tobey Peacock was not a source
of a significant amount of petitioners' cash hoard.
c. Winston MacFarland
Petitioners claim that MacFarland gave them $75,000 in 1983
to buy an interest in the Glenstone property for his stepson, Ki
Chong Kim, because he thought the gift would help save his
marriage to Chang Un MacFarland. The documents relating to
petitioners' purchase of the Glenstone property do not show that
MacFarland was involved in the transaction. Ki Chong Kim's name
was on a deed to the Glenstone property, but he never knew he had
an interest in the property. Petitioners transferred Ki Chong
Kim's interest in the Glenstone property to themselves a few
months after they bought it. Petitioners claim they transferred
the property to themselves because MacFarland told them to do so
after Chang Un MacFarland and Ki Chong Kim moved to Korea and
MacFarland lost hope of reconciliation. We disagree.
MacFarland had few assets when he and Wilma MacFarland were
divorced in 1973. After 1973, MacFarland never reported on his
income tax returns that he had earnings of more than $11,439 per
year. After 1978, he did not report any wage or self-employment
income on his income tax returns. MacFarland worked as an
apartment manager for petitioner-husband from 1980 until the mid-
1980's in exchange for free rent. MacFarland used his Social
Security income to pay his expenses. He was careful not to spend
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