- 10 - On December 31, 1992, petitioners had cash on hand of approximately $60,000 and did not possess cash on hand in any significantly greater amount.2 Petitioners were not mistrustful of banks, and they maintained several bank accounts and engaged in large numbers of banking transactions during both 1991 and 1992. Petitioners’ use of bank accounts included the unusual practice of depositing and writing numerous checks for small amounts. During 1991 and 1992, petitioners deposited 22 checks ranging from $0.63 to $23.47, and also wrote 38 checks ranging from $2 to $9.93. Mr. Black knew that bank deposits are insured by the Federal Deposit Insurance Corporation and that he could have earned considerable sums of interest income, with no risk, if he had deposited the alleged cash hoard into a bank account. Petitioners borrowed money and paid interest on loans during not only 1991 and 1992, but also during prior years when they allegedly were accumulating their cash hoard. Petitioners claimed and respondent allowed, Schedule A, Itemized Deductions, mortgage interest deductions for each of the taxable years 1987 through 1992. Mr. Black borrowed $9,000 from his office manager, Jeanette Roberts, and repaid her during the same year that the loan was made. 2The parties stipulated these facts.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: March 27, 2008