- 24 - 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.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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