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(e) Michael’s Accumulated Savings.--Originally, Michael
told respondent’s revenue agent that, at the beginning of 1994,
he had a cash hoard of $180,000, which he had accumulated over
the years. At trial, Michael testified that he had “Roughly
* * * around 60 to 70,000" in the cash box at the beginning of
1994 and that he “ran out of money a year after I bought the
Metairie Court house”, which he bought on March 24, 1995.
Respondent allowed as a starting 1994 cash hoard only the
remaining net proceeds of the sale of the Newman property,
together with the credit card advances, 1994 child support, and
deposit refund, and treated the entire allowed amount as having
been spent in 1994; respondent has not allowed any starting 1995
cash hoard. Petitioners do not appear to have taken any position
as to how much of their claimed cash hoard was spent in 1994
(except for Sandra’s testimony that she had told Klimkiewicz that
all the remaining net proceeds of the sale of the Newman property
had been spent by the end of 1994), how much was spent in 1995,
and how much was spent (consistent with Michael’s above-quoted
testimony) in early 1996. On brief, petitioners appear to have
abandoned Michael’s $180,000 contention and instead adopted as
their position Michael’s above-quoted trial testimony.
(i) For Cash Hoard
Considerations pointing toward cash hoard include the
following: (1) Respondent has already accepted the idea that
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