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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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