Ronnie F. Judy - Page 16

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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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