- 15 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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