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The disputed categories include petitioners' opening cash on
hand, the ownership of funds in the Bank of Screven County, the
acquisition of a planter in 1985 for use on the Campfield farm,
and petitioner's purchase of casino chips on May 19, 1985, and
November 29, 1986.
Cash on Hand
Petitioners argue that respondent incorrectly determined
cash on hand in the amount of $6,163.95 as of January 1, 1984.
Petitioner contends that he had a cash hoard of $143,000 in a
safe-deposit box located at Connecticut National Bank.
Petitioner contends that the $143,000 cash hoard consisted
of the $66,000 insurance settlement received in 1978 plus
accumulated savings. According to petitioner, he purchased the
cashier's check applied to the Route 3 property using the
$143,000 in cash. For the reasons discussed below, we find that
petitioner did not maintain a cash hoard of $143,000.
On March 31, 1982, petitioner obtained the CNB loan in the
amount of $19,590. Petitioner's borrowing of funds during the
time that he allegedly had a cash hoard supports the inference
that no cash hoard existed. See O'Connor v. Commissioner, 412
F.2d 304, 311 (2d Cir. 1969), affg. in part and revg. and
remanding in part T.C. Memo. 1967-174; Thomas v. Commissioner,
223 F.2d 83, 88 (6th Cir. 1955), revg. and remanding a Memorandum
Opinion of this Court dated Oct. 30, 1953.
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