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Neumyer, the wife of Mr. Neumyer, contained $45,000 in cash, all
$100 bills, and a deposit slip with handwritten notations. Only
Mr. Zaban entered this box. The contents of this box were seized.
Mr. Zaban used the deposit slip notations to keep track of the cash
in the safe deposit box, which indicated the presence of $115,000
in cash on January 2, 1990. On that date, $40,000 was removed; on
January 9, 1990, $20,000 was removed; on February 13, 1990, $10,000
was removed. A balance of $45,000 remained.
Box 2164, held in petitioners' names, contained $40,100 in
cash, all $100 bills, and a deposit slip with handwritten
notations. Mr. Zaban used the deposit slip notations to keep track
of the amount of cash in the box. On January 2, 1990, the deposit
slip notations indicated the presence of $40,100 in cash in the
box, which was placed in the box on January 2, 1990, the same date
and time as the removal of the $40,000 from Box 3567.
D. Loans by Mr. Zaban
Between 1985 and 1989, Mr. Zaban made several large loans.
Sometime prior to December 31, 1985, Mr. Zaban lent $93,100 to F.
Frank Culotta, a friend. In 1988, $30,626 of the aforementioned
loan was repaid upon the sale of an Ocean City, Maryland,
condominium that petitioners owned together with Mr. Culotta. The
balance of the loan to Mr. Culotta remained unpaid as of December
31, 1989. During 1987, Mr. Zaban lent $52,000 in cash to Keith
Vazquez (who is married to Mr. Zaban's niece), which remained
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