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each of the years at issue in at least the amounts of $16,383 and
$21,698, respectively. It is further weakened by the stipulated
fact that he failed to maintain adequate records of his farming
operations.
Even on its own terms, petitioner’s account is not
satisfactory. There are unanswered questions and inconsistencies
that undercut its persuasiveness. First, petitioner did not
offer to explain why Mr. Judy would have preferred to withdraw
the $183,000 he allegedly inherited from his sister and keep it
hidden under his bed rather than leaving it in bank accounts
where it could have earned interest. Such behavior is sufficient
to raise doubts. Cf. Cefalu v. Commissioner, 276 F.2d 122, 127
(5th Cir. 1960), affg. T.C. Memo. 1958-37.
Second, the record discloses that petitioner obtained loans
from unrelated parties during the period that he claims to have
had access to interest-free funding out of his father’s cash
hoard. For example, in November 1990 he borrowed $31,000 from
Dewey Cowart to finance the purchase of real estate. Petitioner
testified that he repaid this loan by the end of that year using
funds from his father’s cash hoard. It is not clear why he felt
he needed a short-term “bridge loan” from Dewey Cowart if he
could have borrowed from the cash hoard in the first place.
Several unreported income cases have noted the apparent
inconsistency between borrowing from third parties and claiming
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