Darrell L. Gaines - Page 17

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          1984, or allowed his truck to be repossessed in 1990.  It is                
          equally unlikely that petitioner, who behaved parsimoniously3               
          with respect to Grand Video, would be willing, as he claimed at             
          trial, to forgo the interest that he would have earned on his               
          cash accumulation if that cash were deposited into an interest-             
          bearing account, especially in those years where his Social                 
          Security and income records indicate that he had little, if any,            
          income.                                                                     
               The pattern in which cash deposits were made to petitioner’s           
          bank accounts also undermines petitioner’s claim to a substantial           
          cash hoard.  According to petitioner, he removed cash from his              
          safe from time to time and deposited the cash into his personal             
          bank accounts.  His explanation is in sharp contrast to the                 
          pattern of cash deposits revealed by his bank records.  Those               
          records indicate that petitioner made frequent cash deposits into           
          his personal accounts at regular intervals during the years in              
          issue.                                                                      
               The foregoing reasons to reject petitioner’s claim that he             
          had a substantial amount of cash in his safe at the beginning of            
          1993 are made more compelling after considering that, at the                
          beginning of 1993, he had in excess of $55,000 on deposit in                


               3 Petitioner recorded in the cash journal many items costing           
          less than $1 and testified that even if a Grand Video receipt had           
          been erroneously completed he would not discard it because each             
          receipt cost approximately $.20.                                            




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