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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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