-32-
Petitioners argue that petitioners did not have more income
than the total amount reported as income on Federal income tax
returns filed by the masseuses.4 We disagree. The masseuses
reported their income based on inaccurate Forms W-2 that they
received from Tokyo Saunas. Thus, petitioners have not
established that the masseuses' returns show how much income
petitioners received.
e. Opening Net Worth-Conclusion
The parties agree that petitioners' opening net worth was
$343,478 before considering the amount of their cash on hand. We
have found that petitioners had $279,000 in cash on December 31,
1982. Therefore, we conclude that petitioners had an opening net
worth of $622,478 on December 31, 1982.
4. Petitioners' 1985 Theft Claim
Petitioners claim that $90,000 in cash was stolen from them
in January 1985, and that respondent's $40,000 opening cash on
hand figure on January 1, 1985, is understated by that amount.
In January 1985, petitioner-wife reported to the Tacoma police
that $90,000 in cash had been stolen from her home. Petitioner-
wife told the police that it had been her mother's money.
4 Before trial, in response to an order of the Court,
respondent gave petitioners the amount of income each masseuse
had reported without showing the masseuses' names.
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