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flowing from our holdings on the above issues. Accordingly, a
decision will be entered under Rule 155.
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference. Petitioners resided in
Hendersonville, Tennessee, at the time the petition was filed.
General Background
During the years in issue, petitioners maintained a cash
hoard in their home. Petitioners separated their cash by
denomination and wrapped it in plastic with rubber bands. The
cash was kept in a wall in their bedroom over some pipes.
Petitioners began accumulating their cash hoard shortly
after they were married in approximately 1966. They preferred to
keep this cash on hand because it gave them a sense of security
if they needed money in a hurry for an emergency. Petitioner did
this to control the household spending and was responsible for
governing the cash hoard.
Petitioner had no set schedule of depositing money to the
cash hoard, nor did he keep any records regarding it.
Petitioners would get cash (from paychecks, reimbursements from
their children for bills paid on their behalf, credit card cash
advances, reimbursements from expenses charged for others on
their credit card, loans from petitioner's mother, and gambling
winnings) and add some to the cash hoard. Petitioner would carry
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