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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".
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