Estate of Frank Johnson - Page 131




                                       - 59 -                                         
          and needed funds himself.24  Accordingly, we find petitioners’              
          allegation that Edward gave Katherine all of his cash, gold                 
          coins, and jewelry implausible and incredible.  We are not                  
          required to accept incredible, implausible, or biased testimony.            
          See, e.g., Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).                 
               Even if we accepted Katherine’s story that Edward gave her             
          all of his cash, gold coins, and jewelry, which we do not, the              
          record contains no verification that any of it remained on hand             
          by the end of 1982.  The record indicates that, over their                  
          lifetimes, Frank and Katherine acquired properties and expensive            
          automobiles and made numerous gifts to their children and                   
          grandchildren.  Larry also acquired expensive automobiles before            
          the years in issue.  Furthermore, the circumstances of Larry,               
          Ronnie, and Sylvia financing some of the cost of the properties             
          and vehicles (for which Frank and Katherine purportedly provided            
          the remaining funds) they acquired during the years in issue are            
          inconsistent with petitioners’ allegation that, at the beginning            
          of 1983, Frank and Katherine were in possession of the                      
          substantial cash hoard they claim.  See, e.g., Appendices B                 
          through I.                                                                  




               24  Petitioners contend that Katherine used some of the                
          money from Edward’s safe deposit box to pay for his                         
          hospitalization.  That contention, however, is not supported by             
          the references to the record they cited.                                    





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