John R. Boone, Jr. - Page 38

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          omitted gross income for 1989 and 1990, or that he had reasonable           
          cause to do so.  Accordingly, respondent's determination that               
          petitioner is liable for the accuracy-related penalty for                   
          negligence for those years must be sustained.  The correct amount           
          of the section 6662(a) accuracy-related penalties for 1989 and              
          1990 will be calculated in a Rule 155 proceeding.                           
               We have considered all other arguments advanced by the                 
          parties and found them to be either irrelevant or without merit.            
          IV.  Conclusion.                                                            
               The record contains credible testimony that petitioner's               
          reputation for truthfulness and veracity in the Springfield,                
          Kentucky, community is good.  Nevertheless, based on our                    
          observations at trial and all of the evidence in the record, we             
          are forced to conclude that there is a substantial lack of candor           
          in petitioner's explanation as to how, when, and from what source           
          he came into possession of the alleged large cash hoard that is             
          the focus of this case.  It is not the Court's function to                  
          speculate as to the actual source of this money, and we decline             
          the opportunity to do so.  We simply do not accept petitioner's             
          version of the truth.                                                       
               To reflect the foregoing and concessions,                              


                                                  An appropriate order                
                                             will be issued, and decision             






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