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b. Dealing in Cash
Throughout the 4 years at issue, petitioners made numerous
and substantial cash expenditures for, among other things, real
property, new luxury automobiles, payments on credit cards,
mortgages, and a host of other personal items. Petitioners kept
large amounts of cash in both their residence and at Moore’s
Auto. Petitioners’ extensive use of cash supports a reasonable
inference that petitioners were knowingly and willfully
attempting to conceal taxable income. See Clayton v.
Commissioner, supra at 647.
c. Participation in Illegal Activity
Lesely pleaded guilty to one count of engaging in illegal
gambling from 1987 through June 1994 under 18 U.S.C. section
1955. While Aljournia might not have participated in illegal
numbers operations, the evidence indicates that she knew or
should have known of Lesely’s involvement. During the 1994
raid, North Carolina law enforcement officers found both lottery
tickets and large amounts of currency in petitioners’
residence.4 Moreover, Aljournia should have known that the cash
4 In her testimony, Aljournia offered inconsistent and
implausible explanations, conceding at one point that lottery
tickets were found in her residence but contending they were
planted there by the law enforcement officials, and at another
point contending, contrary to the evidence, that only one lottery
ticket was found. With regard to the $7,452 in currency found in
her residence, Aljournia argued that “I should be able to have a
few pennies around my house”, contending unconvincingly that the
(continued...)
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