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hoard received by gift from his great-grandfather. By direct
proof this would be almost impossible. But this Court has held
that respondent may negate an alleged nontaxable cash hoard by
proving that such a claim is "inconsistent, implausible, and not
supported by objective evidence in the record." Parks v.
Commissioner, supra at 661; see Boggs v. Commissioner, supra;
Phillips v. Commissioner, T.C. Memo. 1984-133.
For the reasons which follow, we are convinced that
respondent has shown that, more likely than not, petitioner's
1989 and 1990 bank deposits and cash expenditures were not
derived from moneys obtained from his great-grandfather, the only
unagreed nontaxable source asserted in this case.
1. There is no evidence that Walker possessed a cash hoard,
or that he would give it to petitioner if he did.
The objective evidence in the record does not support
petitioner's contention that his great-grandfather possessed a
large amount of cash on hand. In this regard, we note that
Walker's adjusted gross estate was small (roughly $68,000) in
comparison to the alleged cash hoard of approximately $115,000.
Moreover, Walker had miscellaneous real and personal property,
and does not appear to have been the type of individual who was
likely to keep a cash hoard. See Shelhorse v. Commissioner, T.C.
Memo. 1980-98. Walker also had mortgages on his property and
other debts, which is inconsistent with a large cash hoard. See
Thomas v. Commissioner, 223 F.2d 83, 88 (6th Cir. 1955). Also,
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