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Year ending 12/31/92 12/31/93 12/31/94 12/31/95
Cash on hand $200 $200 $200 $200
Cash in banks2 55,201 98,859 142,041 109,560
Personal residence --- 459 459 459
Investment property --- --- --- 83,189
Rental property 20,000 20,306 20,306 20,306
Business assets 87,145 107,099 132,063 151,128
Goodwill 1,000 1,000 1,000 1,000
Prepaid expenses --- --- --- 670
Automobiles 800 12,447 12,147 12,147
The increases in petitioner’s net worth from year to year
are not attributable to gifts, inheritances, or nontaxable
sources of income. In one interview, petitioner told Agent
Keinle that at the beginning of 1993 he had $60,000 in cash in a
safe in his house and approximately $40,000 in cash in that safe
at the end of 1995 (petitioner’s cash hoard). At a subsequent
interview, petitioner estimated that he had $165,000 in cash in
his safe, but later suggested that this figure was a lifetime
high, rather than the amount in the safe at the start of 1993.
Agent Keinle interviewed third parties, reviewed petitioner’s
financial records, and examined petitioner’s tax returns, but she
was unable to corroborate petitioner’s claim that he had
accumulated a cash hoard. She rejected petitioner’s claim of the
existence of a cash hoard and gave him no credit for such in her
net worth analysis.
2 The parties stipulated that “cash in banks” includes
petitioner’s investment accounts and securities.
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