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$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’s
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