-47-
so given the fact that the decedent informed Gonzalez as to the
specifics of his extensive holdings.
We find that the decedent when he died had cash of $50,000
at home. The decedent when he died had amassed at his home
valuable assets worth hundreds of thousands of dollars, and we
believe under the facts and circumstances of this case that it is
reasonable to conclude that the decedent also kept at home a
significant amount of cash. This is especially so given that the
decedent tended to keep his assets secreted at home rather than
in banks (e.g., he kept many of his coins hidden in his garage)
and that he had a history of giving large sums of cash (not
checks) to at least Gonzalez, Polachek, and Wong. He gave
$16,000 in cash to Wong in or about 1987. He gave $50,000 in
cash to Gonzalez and Polachek in 1991. He gave to Wong in or
about 1991 cash of $77,000 and additional money to pay off
approximately $250,000 of her debts. We also note that some of
the receipts in evidence do not relate to the decedent’s checks
in evidence, which indicates to us that the decedent on various
occasions paid large sums of cash for his purchases of the items
which he collected.
e. Coins
Respondent did not recover all of the coins omitted from the
taxable estate. Gonzales understood that the decedent had
approximately 500 coins in the possession of Superior
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