- 12 -
avers that all the cash transactions were from funds accumulated
by petitioner from a 1990 loan to her from NCNB National Bank and
from rental income received by her in prior years. On brief,
petitioner argues that the source of the NCNB deposit was funds
received by petitioner from her children, either as loans or
gifts, as evidenced by the testimony of petitioner and her
children.
Petitioner’s testimony and that of her children concerning
the source of the NCNB deposit conflicted on numerous points and
was not credible. Petitioner’s testimony was particularly
unconvincing concerning the actual times, places, manner, and
denominations of the supposed gifts of cash to her. Petitioner
was not able to remember the details of her son's presenting her
with $10,000 in cash or her daughter's presenting her with
$20,000 in cash. Upon questioning by the Court, petitioner was
not certain when she traveled from California to Florida with the
$10,000 her son supposedly gave her and could not recall whether
she received $20,000 in cash from her daughter in November 1991
or February 1992. The children’s testimony seems particularly
incredible given the large sums of money the children supposedly
gave their mother in comparison to their modest reported incomes
for the years at issue. We do not credit Gary’s testimony that
he kept $15,000 in $100 bills under the carpet in the closet in
his apartment nor his sister Audrey’s testimony that she received
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011