- 30 - 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 wasPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011