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petitioners kept a large amount of cash someplace (not
necessarily in a box) for some period of time--viz the $29,000-
plus remainder of the Newman property proceeds, which was used
from time to time during 1994. (2) Respondent has already
accepted the idea that petitioners on occasion deposited
nontaxable cash receipts into the bank accounts. As noted supra,
respondent agrees that for 1994 petitioners should be allowed to
subtract more in nontaxable cash than petitioners’ 1994 cash
expenditures.
(ii) Against Cash Hoard
Considerations pointing against cash hoard include the
following: (1) Petitioners’ claim of cash hoard, even if
accepted in entirety, would explain only a small fraction of the
otherwise-unexplained omitted income; in the context of clear and
convincing evidence of substantial omitted income in 1995 on the
record herein, it is difficult to credit Michael’s testimony as
to any specific amount. (2) Michael’s testimony as to the cash
hoard, especially in light of his acknowledged earlier
statements, seems to be tailored to his time-to-time perceptions
of what suits his purposes, rather than his best recollection of
the actual events. Michael’s written statement to Klimkiewicz at
the July 1997 meeting was specific in describing why he estimated
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