- 20 - bills, and kept this cash hoard inside a suitcase in an unlocked closet in their residence. We decide whether a witness is credible on the basis of objective facts, the reasonableness of the testimony, and the demeanor of the witness. Quock Ting v. United States, 140 U.S. 417, 420-421 (1891); Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964); Dozier v. Commissioner, T.C. Memo. 2000-255. Having had the opportunity to observe petitioners and Mr. Black’s employee, Mr. Plexico, at trial, we find their testimony regarding the existence of a cash hoard to lack credibility. Petitioners had several bank and investment accounts and made regular use of them. We find it implausible that, as a stockbroker and investment adviser, Mr. Black had accumulated $500,000 in cash, and that he kept that cash in a closet at his house. Respondent repeatedly requested that petitioners provide information about petitioners’ cash on hand, but they refused to provide such information. Petitioners and their representatives were aware that respondent was using the net worth method of proof to compute petitioners’ taxable income for the taxable years 1991 and 1992. However, at no time during Agent McCarter’s civil examination, or Agent O’Dell’s criminal investigation, didPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 NextLast modified: March 27, 2008