Benjamin and Sallie Campfield - Page 15

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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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