- 60 -
Accordingly, on the basis of the entire record, we find that
respondent has shown petitioners’ contention of the existence of
a $750,000 or greater25 cash hoard at the beginning of 1983 to be
inconsistent, implausible, and without objective support in the
record.
Petitioners do not contend, and the record does not suggest,
that Katherine and Frank had accumulated a substantial cash hoard
separate from Edward’s alleged accumulation. Indeed, Katherine
implied the opposite when she testified that “My husband didn’t
believe in banks. We spent it as we got it to raise the
children.” Nonetheless, on the basis of the entire record, we
believe that throughout the years Frank and Katherine maintained
a practice of keeping cash on hand (as evidenced by the amount of
cash in their home safe when Jack White burglarized their home in
1990). In our best judgment, based on the entire record, we
estimate that amount to be $30,000. See Mikelberg v.
Commissioner, 23 T.C. 342, 352 (1954), affd. per curiam 234 F.2d
25 Petitioners contend that the dramatic increase in the
price of gold substantially increased the value of the gold coins
and jewelry that Katherine received from her father; thus, that
increased the amount of the available cash hoard. Even if we had
accepted Katherine’s cash hoard story, the record does not
establish how much of the coins and jewelry she sold or when they
were sold. In her deposition, Katherine testified that she kept
the jewelry until she was robbed in 1990, and then she gave some
away to relatives and sold some to other Gypsies. She never
testified as to when she sold the items, the number of items
sold, or the price that she received for them. Katherine made no
mention of the disposition of the gold coins.
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