Estate of Leon Spear, Deceased, Jeannette Spear, Harvey Spear, and Robin Spear, Administrators, and Jeannette Spear - Page 3

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          Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647,           
          102 Stat. 3342, 3743-3746.  Rule references are to the Tax Court            
          Rules of Practice and Procedure.                                            
          A.   Petitioners                                                            
               Leon Spear (the decedent) and Jeannette Spear (Mrs. Spear)             
          lived in Philadelphia, Pennsylvania, when they filed their                  
          petition.  They operated parking lot businesses from 1956 through           
          the years in issue and dealt extensively in cash.                           
               The decedent and Mrs. Spear kept cash in safe deposit boxes            
          and entered their safe deposit boxes many times from 1972 to                
          1977.  They destroyed the records of their cash receipts from               
          their parking lot businesses, including daily settlement sheets,            
          before respondent's audit.                                                  
          B.   Respondent's Investigations of the Decedent and Mrs. Spear             
               Respondent's agents interviewed the decedent and Mrs. Spear            
          and sent document requests to them before respondent issued the             
          notice of deficiency.  Respondent interviewed the decedent and              
          Mrs. Spear's Federal income tax preparer and a bookkeeper for               
          their corporations.  Respondent summoned third parties, reviewed            
          public records, and examined the decedent and Mrs. Spear's bank             
          accounts and financial statements.                                          
               On December 9, 1977, Revenue Agent Michael McGuckin                    
          (McGuckin) asked the decedent and Mrs. Spear how much cash they             

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