- 21 - petitioners or any of their representatives claim that the net worth adjustments could be explained by the use of a large cash hoard. Petitioners did not raise any cash hoard defense in either their petition or their reply. Petitioners first raised their cash hoard defense only after this case initially was set for trial in Winston-Salem, North Carolina, on May 23, 2005. Petitioners have failed to identify any source of funds for the cash hoard other than supposed savings over a number of years. On the July 26, 1985, consumer loan application to Home Federal, petitioners stated that they possessed “Cash on hand and in banks” totaling $9,000. During Agent Helton’s examination of petitioners 1987 through 1989 taxable years, petitioners failed to identify any large quantities of cash on hand. At trial, Mr. Black testified that he had lied to Agent Helton. Furthermore, all of the expenditures in respondent’s net worth calculations are by check or credit cards eventually paid by check. Also, there is no evidence of large cash deposits into petitioners’ bank accounts. Thus, even if petitioners had a cash hoard, it would not affect the net worth calculations as there is no evidence that any of the expenditures were paid by cash either directly or through deposit and payment by check.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: March 27, 2008