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his Social Security records, his Federal income tax returns for
1979 and 1980, and his former partner, who testified at trial,
indicate otherwise.
A claim of the existence of a cash hoard is often “met with
some suspicion”, De Venney v. Commissioner, 85 T.C. 927, 933
(1985), and we are more than somewhat suspicious of petitioner’s
claim in this case. Ignoring for the moment petitioner’s
inconsistent statements as to the amount of his cash hoard, after
careful consideration of other evidence in the record we, like
respondent, reject his claim.
His earning history over the years, as indicated by Social
Security and income tax records, does not support the
accumulation of cash in any amount claimed by petitioner. See
Petzoldt v. Commissioner, supra at 692. According to petitioner,
he led a frugal lifestyle for most of his adult life and was able
to accumulate cash savings to the extent claimed. Although they
do not provide a complete picture of his earnings, petitioner’s
Social Security records, when coupled with information in the
record regarding his Federal income tax returns filed in years as
far back as 1967, make petitioner’s claim that his frugal
lifestyle allowed him to accumulate a substantial cash hoard
completely incredible. Moreover, if petitioner had access to the
amount of cash he claimed, we think it highly unlikely that he
would have allowed his house to be sold in a foreclosure sale in
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