- 43 -
income received between 1982 and 1987 admitted into evidence, see
table supra p. 18, indicates that the Takaos received interest
income from banks during that period of $306,499. Interest of
that amount would suggest that the Takaos maintained a
substantial principal balance in the banks during those years.
Yoshinori, Motomi, and Nakamura testified that Akiko
maintained a cash hoard in her home before and during the years
in issue as well as at the time of her death. However, none of
them knew the amount of cash Akiko had on hand as of January 1,
1988, or the cash that remained at the end of the years in issue.
They did not know whether any deposits Akiko made during the
years in issue came from that cash hoard.
Yoshinori testified that Akiko began depositing money in
1988 after an employee of the bank advised Akiko she could earn
interest on deposits. Petitioners also contend that Akiko made
deposits from her cash hoard after Nakamura warned her in 1989
that it was dangerous to keep cash in the house. That testimony
seems to be belied by the apparently large principal balances
Akiko maintained in bank accounts before and during the years in
issue. It also is contradicted by Motomi's testimony that Akiko
had a large sum of money on hand at the time of her death. We do
not doubt that Akiko kept some cash on hand in years before and
during the years in issue. However, we are unable to find from
this record the amount, if any, of the questioned cash deposits
that came from cash accumulated before January 1, 1988.
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