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return than the interest that they were earning on their checking
and/or savings bank accounts, and refinance the mortgage loan on
their house when interest rates fell below the interest rate
applicable to that loan, would not forgo the ability to earn
interest income on petitioners' alleged cash hoard of $332,000
(or even $200,000), especially considering the high interest
rates available during the 1980's, which peaked at 20 percent in
1982. Considering those high interest rates, petitioners would
have forgone interest income of as much as $60,000 a year by
keeping the alleged cash hoard of $332,000 at home and not
depositing it into banks. That amount of forgone interest income
is more than petitioners reported as total income for any of the
years 1986 through 1991. We do not believe that petitioners
would have forgone such interest income, and we do not believe
that they did. That is because we do not find credible their
claim that their cash hoard of $332,000 (or $200,000) was the
source of the bank deposits at issue.
It is also significant that Mr. Mifsud testified at trial
that he could not recall the amount of petitioners' alleged cash
hoard that they deposited into their bank accounts during each of
the years at issue. We find Mr. Mifsud's claimed inability to
remember those alleged matters to be suspect in view of his
ability to remember with specificity other facts relating to
petitioners' financial situation. For example, Mr. Mifsud was
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