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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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