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sources, they are taxable to SCC. Dodge v. Commissioner, 981
F.2d 350, 353 (8th Cir. 1992), affg. in part, revg. in part and
remanding in part 96 T.C. 172 (1991). Petitioners argue that the
deposits in question were from cash that Mr. Strong accumulated
over the years.
SCC clearly had a taxable source of income as it was in the
construction business during the years at issue. The amounts
were deposited to bank account No. 893315300, as were the
proceeds from the 22 house sales. Mr. Strong did not point to
any source for the deposits other than his previously accumulated
funds.
Mr. Strong alleges he began to accumulate cash through
gambling winnings during his service in the U.S. Navy in the mid-
1970s. He claims to have maintained a substantial cash hoard
throughout his marriage from 1978 to 1989 and during his filing
under chapter 7 of the Bankruptcy Code in 1990. Mr. Strong’s
assertions are not credible for several reasons. First, Mr.
Strong was unable to explain specifically how the cash was
obtained, where it was maintained, its amount after 1978, and how
it was used. He stated that he was basically guessing when asked
to specify what amounts he had on hand at any particular point.
On cross-examination regarding the nature of his cash hoard, Mr.
Strong refused to be specific and continually changed his story.
For example, he stated that he did not add to his cash
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