- 23 - 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 specificallyPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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