- 30 - 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 ofPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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