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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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