James E. and Chung H. Peacock - Page 24

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          more than the amount of his Social Security checks.  Petitioner-            
          husband occasionally gave MacFarland small amounts of money.  The           
          two-bedroom house that MacFarland built and occupied was                    
          unfinished and had very little furniture.  There is no credible             
          evidence that MacFarland contributed $75,000 to buy the Glenstone           
          property.  The documents associated with petitioners' purchase of           
          the Glenstone property do not show that MacFarland was involved.            
          The person for whom MacFarland allegedly bought the property, Ki            
          Chong Kim, did not know he had an interest in the property.  We             
          conclude that MacFarland did not contribute $75,000 to buy the              
          Glenstone property.                                                         
                    d.   Petitioner-Husband's Claimed $200,000 From                   
                         Skimming and Black Market Sales in Vietnam                   
               Petitioner-husband claims that he brought $200,000 in cash             
          to the United States when he returned from Vietnam.  He testified           
          that he got the $200,000 in Vietnam during 1970 and 1971 by                 
          skimming money from U.S. Army slot machines and by selling beer             
          and soda on the black market.  Petitioner-husband testified that            
          he did not tell anyone except petitioner-wife about his                     
          activities in Vietnam because he did not want people to know he             
          had a lot of cash, and that they did not make this claim when he            
          was being prosecuted for income tax evasion for 1987 because he             
          knew that his actions had been illegal.  Petitioners first made             
          this claim during the trial of this case.  We are not convinced             
          by petitioners' belated claim that petitioner-husband brought a             





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