- 26 - 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.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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