John R. Boone, Jr. - Page 30

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          things, with the fact that he took thousands of dollars of                  
          traveler's checks on trips to avoid losing cash.                            
               Moreover, we think it implausible that petitioner would take           
          out student loans if he had been given the money to use for                 
          "something purposeful".  We also do not think that petitioner               
          would take out the loan for the Mustang at a relatively high                
          annual percentage rate if he had a large cash hoard at the time             
          he bought the car, only to pay the loan off with cash several               
          months later.  Evidence of borrowing supports an inference that             
          petitioner had no cash hoard, as a cash hoard obviates the need             
          to borrow.  See Thomas v. Commissioner, 223 F.2d at 88.  Even if            
          we believed that these actions could be explained as a                      
          consequence of petitioner's efforts to hide the money from his              
          family in keeping with his great-grandfather's alleged wishes,              
          petitioner never showed any large cash assets on documents that             
          his family would never have reason to see, such as his mortgage             
          application.                                                                
               Also, we think it unlikely that petitioner would forgo                 
          earning interest on such a large sum of money.  See Conti v.                
          Commissioner, T.C. Memo. 1992-616, affd. and remanded to correct            
          a computational error 39 F.3d 658 (6th Cir. 1994); Cruz v.                  
          Commissioner, T.C. Memo. 1990-594; Phillips v. Commissioner, T.C.           
          Memo. 1984-133.  Petitioner had a savings account from a very               
          young age, and interest earned on the large amount of money would           
          have provided him with a sizable sum relative to the amount of              




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