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maintained in a safe at Gene’s and was used by petitioner and his
family for personal expenses.
Petitioners argue that additional bank deposits should be
eliminated as nontaxable because they represent cash gifts from
petitioner’s parents. Petitioner, his parents, and several close
relatives testified that petitioner’s parents received cash from
Korea, and that cash gifts were made to petitioner by his
parents. The record reflects that petitioner’s father had
instituted a lawsuit in Korea and that he had won a judgment in
his favor. The record also reveals that the judgment was
appealed and that petitioner’s father was successful on appeal,
but the appeal did not conclude until May 1993. Respondent
points out that under the laws of Korea, petitioner’s parents
were not entitled to expatriate the proceeds of the judgment from
Korea to the United States. There is also evidence in the record
that certain American Express traveler’s checks did not become
available to petitioner’s parents until sometime during 1994.
In an attempt to show that petitioner’s parents had the
means to make gifts, petitioners offered the testimony of close
relatives (uncles, aunts, etc.), each of whom testified that on
specific dates in 1991 and 1992 they received large amounts of
cash ($20,000 to $30,000) on behalf of petitioner’s parents. The
witnesses each stated that they received the cash in stacks of
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