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to have a cash hoard at one’s disposal. Id. at 127; Peters v.
Commissioner, T.C. Memo. 1981-83; Stutts v. Commissioner, T.C.
Memo. 1975-298.
Third, petitioner’s explanation of the circumstances under
which he began using the cash hoard conflicts with other
statements he made both before and during the trial. Petitioner
told the Court that he sustained heavy crop losses from Hurricane
Hugo in September 1989. “It destroyed our corn and soybean crop,
and that is the year I started borrowing money out [of] the
Ellis’ estate to pay bills.” But Cox testified that petitioner
told him that he had borrowed funds from the Ellis inheritance to
finance specific purchases of equipment in 1987 and land in 1988.
Petitioner never specifically denied Cox’s account of this
interview. Moreover, on the morning of the trial he produced
documentation showing, to the satisfaction of respondent’s
counsel, that he had purchased a tractor trailer in 1988 rather
than in 1989, as respondent had assumed in the source and
application of funds computation set forth in the notice of
deficiency. He later testified that the money he used to
purchase the tractor trailer came from his father’s cash hoard.
Finally, petitioner has failed to give either the IRS or the
Court a plausible estimate of the total amount he allegedly
borrowed from the cash hoard. Cox testified that during the
investigation petitioner “never would give us a specific amount
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