John R. Boone, Jr. - Page 26

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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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