Eddie Lee Williams - Page 9

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          kept the cash through this period of time despite attempts by               
          credit card issuers to collect from him on outstanding debts.               
               Our evaluation of petitioner’s testimony is founded upon               
          “the ultimate task of a trier of the facts--the distillation of             
          truth from falsehood which is the daily grist of judicial life.”            
          Diaz v. Commissioner, 58 T.C. 560, 564 (1972); see also Tokarski            
          v. Commissioner, 87 T.C. 74, 77 (1986).  We do not find to be               
          credible petitioner’s uncorroborated testimony concerning the               
          credit card cash advances.  We find it unlikely that petitioner             
          was able to secure such large cash advances, that petitioner with           
          the help of his father then hoarded these cash advances for                 
          several years, and that petitioner then began depositing this               
          money in small amounts into bank accounts.                                  
               We find that petitioner did not have a cash hoard prior to             
          the years in issue, and that he instead was using proceeds from             
          the drug sales to make the cash expenditures and cash bank                  
          deposits in question.  Accordingly, we sustain respondent’s                 
          determination that petitioner received unreported income in the             
          amounts reflected in the notice of deficiency, income which is              
          includable in petitioner’s gross income and subject to Federal              
          income taxation under sections 1 and 1401.4                                 


          4  Petitioner has cited various statutes and cases in                       
          support of his contention that the income at issue is not                   
          taxable.  We need not address these arguments in detail.                    
          Respondent’s determinations are in accordance with the law, as              
          discussed above, and the law cited by petitioner is not                     
          applicable to the case at hand.                                             





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