Larry Dean Sykes and Ruby Sykes - Page 17




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          bonds in his car” when petitioner visited him in the early                  
          1980's.  He also saw petitioner with “hands full of money” and “a           
          considerable sum” of money.                                                 
               3.   Whether Petitioners Introduced Credible Evidence of the           
                    Existence and Amount of Petitioner’s Cash Hoard                   
               Petitioners introduced credible evidence that petitioner had           
          a cash hoard, such as the fact that he entered his safe deposit             
          box 53 times from December 1987 to March 1998 and that his family           
          saw him with large amounts of cash over the years.  However,                
          petitioners did not introduce credible evidence that petitioner             
          had accumulated $149,200 before 1997.  Petitioner testified that            
          he received a $6,000 settlement from International Paper because            
          he cut his finger while on the job.  However, he did not state              
          when the injury occurred or when he received the money.  He did             
          not mention the alleged payment in the jeopardy assessment                  
          proceeding or to respondent before the trial in this case.                  
          Petitioner’s explanation of his grandmother’s alleged $20,000               
          gift to him changed over time.  He told Fridley that he received            
          $20,000 from his grandmother’s estate in 1992.  He stated in his            
          December 1999 affidavit prepared for the jeopardy assessment                
          proceeding that his grandmother gave him $20,000 in 1986 to                 
          replace valuable items he had kept in her house and then lost in            
          a house fire.  At trial, he testified that his grandmother gave             
          him $20,000 shortly before she went into the nursing home; i.e.,            
          around 1990.                                                                





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