James E. and Chung H. Peacock - Page 26

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               Petitioners contend that the fact that they used an ice                
          chest to transport cash to Las Vegas establishes that they had a            
          large amount of cash on hand.  Petitioners' proof is vague at               
          best.  There is no credible evidence about the amount of cash in            
          the ice chest.  Petitioners did not prove the denominations of              
          the bills in the bucket, grocery bag, or ice chest.                         
               Petitioners contend that the $287,000 difference between the           
          listed liquid assets and the $590,000 subtotal for liquid assets            
          on a loan application dated April 15, 1985, shows that they had a           
          large cash hoard at that time.  We disagree.  The difference is a           
          mistake, not evidence of a cash hoard.  Petitioners make a                  
          similar mistake under nonliquid assets where they report that               
          $590,000 for liquid assets plus $80,000 for automobiles, and                
          $100,000 for furniture and personal property equals total assets            
          of $921,000.                                                                
                    g.   Conclusion Regarding Cash Hoard Sources Alleged by           
                         Petitioners                                                  
               We conclude that petitioners vastly exaggerated the amount             
          of cash they received from these sources.                                   
               2.   Respondent's Skim Formula                                         
               K.C. Urbon picked up the daily sheets and cash from the                
          saunas for 3 months in 1987.  Pursuant to petitioner-husband's              
          instructions, K.C. Urbon reported 3/7 of petitioners' share of              
          the receipts to petitioners' bookkeeper.  Applying the 3/7                  







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