Timothy Dean Strong - Page 23

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          accumulation for 6 years, from 1982 through 1988.  Later, upon              
          being questioned by the Court, Mr. Strong stated that he did add            
          to his cash accumulation during that period.  Still later, Mr.              
          Strong decided that his cash accumulation would have been in one            
          of three bank accounts.  We construe against him Mr. Strong’s               
          failure to provide adequate details regarding his cash hoard.               
          “We are not required to accept implausible, uncorroborated, and             
          incoherent contentions as to the existence of a cash hoard.”                
          Daniels v. Commissioner, T.C. Memo. 1992-692.                               
               Second, even though Mr. Strong was married during the period           
          he held his cash hoard, his ex-wife was unaware that it existed.            
          His ex-wife testified that the couple did not have an excess of             
          cash during the 8 years they were living together.  Further, Mr.            
          Strong did not disclose the existence of the cash hoard upon                
          their divorce, even though he stated under penalties of perjury             
          in that proceeding that he had disclosed all assets.                        
               Third, Mr. Strong’s liabilities are inconsistent with his              
          claimed cash hoard.  For instance, Mr. Strong and his then wife             
          lost at least three properties through foreclosure from December            
          1986 through February 1988.  Such a forfeiture is inconsistent              
          with the existence of a cash hoard.  See Holland v. United                  
          States, 348 U.S. 121, 133 (1954).  Mr. Strong also borrowed                 
          $10,000 in 1991 to purchase equipment and allegedly borrowed                
          $6,000 from his father in December 1990.  Mr. Strong specifically           






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