Benjamin and Sallie Campfield - Page 16

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               Petitioner maintained an interest-bearing money market                 
          account during the years 1984 through 1986.  In 1984 and 1985,              
          petitioner placed substantial sums of money in this account.                
          These transactions indicate that petitioner was not mistrustful             
          of banks, and we find it unlikely and improbable that petitioner            
          would forgo interest on the $143,000 allegedly kept in the safe-            
          deposit box.  See Conti v. Commissioner, T.C. Memo. 1992-616,               
          affd. in part and revd. and remanded in part 39 F.3d 658 (6th               
          Cir. 1994).                                                                 
               Petitioner waited until trial to assert that he had a cash             
          hoard, and he made no such claim to respondent's agents.                    
          Petitioner's delay in claiming the existence of a cash hoard is a           
          factor that weighs in respondent's favor.  See United States v.             
          Gay, 567 F.2d 1206, 1207 (2d Cir. 1978).                                    
               Petitioners reported adjusted gross income of $26,197 and              
          $13,206 for the taxable years 1982 and 1983, respectively.  We              
          find it unlikely that petitioners could have accumulated a                  
          significant cash hoard from this income.                                    
               We find that petitioner did not maintain a cash hoard in the           
          safe-deposit box at Connecticut National Bank as of January 1,              
          1984.                                                                       
               Funds in the Bank of Screven County                                    
               Respondent's net worth and expenditures computations                   
          included cash in banks.  Respondent determined that petitioner              






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