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items listed in the inventory, except for the homestead, belonged
solely to Mr. Riffe.
Petitioners contend that respondent did not prove that the
$268,000 in cash from the safe deposit boxes which was deposited
in the C&S bank account did not belong jointly to Mrs. Pert and
Mr. Riffe. Petitioners contend that the Pinellas County
Sheriff's office returned the $132,000 cash seized from safe
deposit box 204 to Mrs. Pert, individually, and not to Mr.
Riffe's estate. We disagree. The Sheriff's office required Mrs.
Pert to present letters of administration before releasing the
cash. The receipt which Mrs. Pert signed states that the
authority to release the cash was the probate of Mr. Riffe's
estate as shown by letters of administration. We conclude that
the seized cash was released to Mrs. Pert in her capacity as
personal representative of Mr. Riffe's estate.
Petitioners contend that respondent offered no evidence
showing that the other $136,000 included in the $268,000 was
solely Mr. Riffe's property or that it was Mr. Riffe's and not
Mrs. Pert's property. We disagree. Mrs. Pert did not know about
any of the cash in Mr. Riffe’s safe deposit boxes. Mrs. Pert
told respondent's revenue agent on February 28, 1991, that she
did not know that Mr. Riffe had any cash on hand. She also told
him that she had no money or sources of funds and that she had to
borrow money from friends and family because she had no signature
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