- 16 - 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 amountPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011