- 92 - $100,000 in jewelry on December 5, 1989, when Revenue Officer Budde prepared the collection statement, then Frank and Katherine must have accumulated $30,000 cash and $100,000 in jewelry between the date of the collection statement and the date of the theft. Petitioners contend, however, that there is no evidence that the cash and jewelry were accumulated between those dates. We agree with petitioners. On the basis of our review of the entire record, we believe that the collection statement did not accurately list all of the assets Frank and Katherine owned as of December 5, 1989. We have made a finding of fact that Frank and Katherine had cash on hand of approximately $30,000 as of January 1, 1983, and that throughout the years in issue Frank and Katherine kept approximately $30,000 cash on hand at the beginning and end of each year. Thus, there was no net change in the amount of cash on hand during the years in issue. In addition, we believe that Frank and Katherine accumulated significant amounts of jewelry over their lifetimes. The record does not establish that Frank and Katherine purchased any jewelry during 1990. It is not clear, furthermore, that all of the jewelry in their safe actually belonged only to Frank and Katherine. Frank and Katherine had a lifelong practice of gifting property, including jewelry, to their children and grandchildren. Some of their children’s and grandchildren’sPage: Previous 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 Next
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