Eddie M. and Cynthia L. Chandler - Page 14

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          respects.  First, they contend that respondent's analysis failed            
          to credit them with cash on hand at the beginning of 1989.                  
          Second, they contend that respondent's analysis overstated their            
          expenditures for 1989 and 1990.  Third, they contend that                   
          respondent's analysis erroneously charged them with $20,000                 
          derived from drug trafficking in 1990.  As discussed below, we              
          reject petitioners' first and third contentions; however, we                
          agree in part with their second contention.                                 
               Based principally on the testimony of petitioner at trial,             
          petitioners contend that they had cash on hand at the beginning             
          of 1989 in the approximate amount of $2,000 to $4,000.  However,            
          we are unable to accept uncritically petitioner's testimony to              
          this effect.  See Tokarski v. Commissioner, 87 T.C. 74, 77 (1986)           
          (the Court is not required to accept a taxpayer's self-serving              
          testimony as gospel).  Apart from our evaluation of the witness,            
          we note that petitioner's testimony stated no more than that he             
          maintained cash on hand "on a pretty consistent basis".  Thus,              
          there was no testimony that cash on hand held at the beginning of           
          1989 was actually expended during either 1989 or 1990.                      
               We also reject petitioner's testimony that he was never                
          involved in either the production, distribution, or sale of                 
          marijuana, and that he never possessed marijuana or even saw a              
          marijuana plant.  See Tokarski v. Commissioner, supra.  We do not           
          think that petitioner would have pleaded guilty to a drug-related           
          felony charge if the foregoing statements were true.  We also               




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