Beatrice DiPierro - Page 13




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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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