Michael London - Page 54

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             cash hoard obtained as gifts from petitioner's mother,                   
             Mrs. Ida London.  According to petitioners, Mrs. Ida London              
             gave them cash from Treasury bonds and other securities,                 
             worth from $149,000 to $200,000, the proceeds from the sale              
             in 1980 of Mrs. Ida London's property at 400 and 402                     
             Broadway in the amount of $27,000, the proceeds from the                 
             sale in 1981 of Mrs. Ida London's home at Franklin Avenue                
             in the amount of $28,000, Treasury bills and certificates                
             of deposit in an amount from $100,000 to $200,000, and                   
             occasional cash gifts.  Petitioners argue that respondent's              
             "disregard of a possible cash hoard (bond proceeds and                   
             other property of Ida London) and disregard for the                      
             existence of a plausible explanation as to the informal                  
             transfer of parental property to their only child, only                  
             daughter-in-law, and grandchildren, indicates that the net               
             worth statement is wrong and cannot retain its presumption               
             of correctness in this case."                                            
                  At the outset, we note that the record as to each of                
             the assets that petitioner's mother allegedly gave to                    
             petitioners is vague as to the amount of the asset and the               
             time that she allegedly transferred it to her son and his                
             family.  For example, Mrs. London testified that her                     
             mother-in-law had "close to $200,000" in bonds whereas a                 








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