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plus gold coins and jewelry worth around $50,000 to $60,000 at
the time of transfer. Additionally, they assert that the value
of gold increased substantially over the years thereby providing
a larger available cash hoard for the years in issue. Respondent
disputes petitioners’ claim of a cash hoard. Rather, respondent
asserts that Frank and Katherine could not have had cash on hand
at the beginning of 1983 in the amounts claimed by petitioners.
We agree with respondent.
In her deposition, Katherine told conflicting stories
relating to the acquisition of a cash hoard she allegedly
received from her father. According to one of those stories, to
keep Bolita from taking Edward’s money while he was in New York
City Hospital to have his leg amputated, Katherine and her
brother Jack21 went to Edward’s safe deposit box at Chase
Manhattan Bank and removed cash totaling $750,000 (in nothing
less than $100, $500, and $1,000 dollar bills), plus gold coins
and jewelry worth at the time between $50,000 to $60,000.
According to that story, Katherine returned to her home in
Florida with the cash, gold coins, and jewelry carried in a gypsy
pillowcase, and she kept Edward’s property in her home in
Callahan, Florida, and later in Longwood, Florida, or in a safe
21 Petitioners did not offer any evidence from Jack
relating to Edward’s cash hoard or explain why Jack was
unavailable. Katherine testified in her deposition both that
Jack had died 6 or 7 years before the deposition, and that he was
living in an unknown location in England.
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