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significant amount of cash to the United States from Vietnam or
that they still had it on December 31, 1982.
e. Petitioners' Claimed Cash Hoard From Previously
Taxed Income
Petitioners' claim that they had more than $60,000 on
December 31, 1982, that they had saved from previously taxed
income was vague and unsubstantiated. We believe, however, that
they had saved a substantial amount of cash from previously
untaxed, skimmed income since they had been operating massage
parlors since 1972.
f. Physical Evidence of Petitioners' Cash Hoard
Petitioners contend that they have shown that they had more
than $660,000 of cash on hand at the beginning of 1983 because at
least $500,000 could fit into a 5-gallon plastic bucket like the
one they buried in their yard or a grocery bag like Michael Koon
saw. We disagree. Respondent does not dispute that $500,000
could fit into a 5-gallon bucket or a grocery bag if the
denomination of the bills were large. However, there is no
evidence that more than $100,000 was ever counted.
Many people saw that petitioners had a large amount of cash.
However, the only witness who said he counted any of petitioners'
cash, Michael Koon, said that he counted $100,000 and that he
believed he had counted about one-third of the cash that was
present.
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