Timothy Dean Strong - Page 24

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          testified that he borrowed from his father in 1990 because he               
          “was short on cash”.  Borrowing money and incurring interest                
          charges are inconsistent with sitting on a large amount of                  
          unproductive cash.  Thomas v. Commissioner, 223 F.2d 83, 88 (6th            
          Cir. 1955), revg. a Memorandum Opinion of this Court; Daniels v.            
          Commissioner, supra.                                                        
               Fourth, Mr. Strong’s prior years’ tax returns are                      
          inconsistent with his claim that the cash hoard came from                   
          previously taxed income.  From 1981 through 1989, he reported               
          taxable income of $59,789, an average of $6,643 per year.2  The             
          largest taxable income he reported was $24,184 in 1981, and in              
          1984, 1985, 1987, 1988 and 1989, he reported zero taxable income.           
          This was at the same time he was supporting three children.  Mr.            
          Strong’s reported income from 1981 to 1989 is not sufficient to             
          live on, much less accumulate a large cash hoard.  See Holland v.           
          United States, supra.                                                       
               Finally, Mr. Strong filed for chapter 7 bankruptcy                     
          protection in March 1990.  In his bankruptcy case, he represented           
          that the sum total of his assets equaled $33,500, including his             
          homestead valued at $30,000.  He alleged he had no cash on hand             
          and no interest in any corporation.  These representations                  
          plainly contradict his current assertion that his cash deposits             
          during the years at issue were from cash on hand at the beginning           

               2SCC reported no taxable income during this same period.               




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