- 15 - 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 claimingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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