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Walker's safe deposit box contained no cash at the time of his
death.
Petitioner would have the Court conclude that, since Walker
had no bank accounts and no cash in his safe deposit box at the
time of his death, he must have possessed a sizable cash hoard.
However, it is more likely that Walker was "dirt rich" and cash
poor. In any event, we doubt that, if Walker had such a cash
hoard, he would have kept it in a desk drawer, in a small
building located apart from his house in town, while he kept no
cash in his safe deposit box, where it would not be subject to
theft or casualty. See Shelhorse v. Commissioner, supra.
Moreover, in his will, Walker left all of his property to
Susanna and Jean, the natural objects of his bounty, making no
provision for petitioner or any other of his descendants. No
gift tax return was filed by or for Walker. Furthermore, there
is no evidence that Walker ever told anyone about a cash hoard or
a gift to petitioner. We do not think that the fact that
petitioner was a tag-along companion who assisted his great-
grandfather toward the end of his life would have imbued Walker
with the desire to give his 11-year-old great grandson, three
generations removed from him, almost twice as much as he
bequeathed to his wife and daughter.
2. Petitioner's testimony is implausible, is not supported
by objective evidence, and is inconsistent with prior
statements he made to respondent's agent.
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