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During 1971, Frank purchased a 1971 Corvette for $4,160.
Frank purchased a 1967 Rolls Royce during 1982 for $18,500. He
paid cash for the vehicle, primarily in $100 bills.
As of January 1, 1983, Katherine and Frank had cash on hand
of approximately $30,000. Throughout the years in issue, they
kept approximately $30,000 cash on hand at the beginning and end
of each year.
At a meeting with Frank and Katherine on or about
December 5, 1989, Revenue Officer Budde prepared a Form 433-A,
Collection Information Statement For Individuals (collection
statement), on the basis of information provided by them. The
collection statement, among other things, indicated that Frank
and Katherine’s only assets were (1) two bank accounts of $1,200
and $13,000 at Glendale Federal, (2) a residence valued at
$60,000 and monthly payments of $500, (3) a 1986 Cadillac having
zero value, and (4) a 1986 Chevy having zero value. The
collection statement further indicated that Frank and Katherine’s
only source of income at that time consisted of $900 per month in
Social Security benefits.
Larry purchased a 1977 Corvette during 1977 for $3,480.
During 1982, Larry purchased a 1978 Chevrolet Suburban for
$2,699.
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