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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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