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more than $30,000 in cash gifts at her wedding, which she kept at
home, in her closet (in a safe). We observed the demeanor of
petitioner and her children and do not believe that any of them
told the truth with respect to the source of the NCNB deposit.
We may reject testimony that is inherently improbable or
manifestly unreasonable, even where no contradictory testimony is
offered. See, e.g., Boyett v. Commissioner, 204 F.2d 205, 208
(5th Cir. 1953), and the cases cited therein. We accord the
testimony of petitioner and her children no weight with respect
to the source of the NCNB deposit. Petitioner has failed to
prove her claim of a nontaxable source.
5. 1993 Adjustment
Respondent adjusted petitioner’s 1993 gross income on
account of the Fortune Bank deposit ($10,000 deposited into an
account of petitioner’s on December 8, 1993) and the NationsBank
purchase ($11,250 used to purchase a cashier’s check on
December 9, 1993). Petitioner argues that petitioner’s reported
income (principally from real estate) explains those cash
transactions.
Petitioner has attempted to show from known bank deposits
and sources of income that petitioner did not fail to report all
of her income for 1993. Petitioner’s analysis is flawed. There
is in evidence a “Statement of Account Activity” for Hawthorne
Savings and Loan Association account No. 10130059-8 (the first
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