- 58 - (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 thatPage: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 Next
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