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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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