- 11 - of January 1, 1980. By his plea, petitioner thus implicitly admitted that he had no cash hoard as of January 1, 1980. Additionally, there is ample evidence that petitioner experienced serious financial problems between 1976 and 1978 when his assets were in receivership. Petitioner's allegation of a cash hoard was inconsistent, implausible, and not supported by objective evidence in the record. See Parks v. Commissioner, 94 T.C. 654, 661 (1990). We therefore conclude that petitioner did not have a cash hoard as of January 1, 1980. C. Petitioner's Sale of Poppers Petitioner alternatively argues that his unreported income was attributable to his sale of "poppers"2 on behalf of the Screening Room and that E&A of CA, and not petitioner, should be taxed on the income from the sale of poppers. From petitioner's testimony, it is unclear how petitioner acquired the poppers, if and how petitioner transferred the poppers to the Screening Room, the quantity sold, and the price at which they were sold. Petitioner's testimony was vague and contradictory as to this matter. See Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Even if we were to believe that petitioner, acting as a representative of the Screening Room, 2 "Poppers" consist of a substance which a person inhales "to get high".Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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