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banks. Accepting petitioner’s claim would require a finding
that, at the beginning of 1993, petitioner had cash savings that
substantially exceeded the total amount of his earnings during
the prior 30 years. To the extent that petitioner was able to
accumulate cash savings over the years, we are satisfied that the
$55,201 credit for “cash in banks” that petitioner was given in
respondent’s net worth analysis adequately accounts for those
savings.
We reject petitioner’s claim that respondent’s net worth
analysis is flawed. We find no error in respondent’s failure to
take into account any cash accumulation not already accounted for
in the net worth analysis. Petitioner does not claim that the
analysis is incorrect in any other way. Furthermore, statements
made by petitioner in investment account and credit card
applications support respondent’s computations of petitioner’s
income for at least two of the years in issue. Consequently,
respondent’s determination of the deficiency, as stipulated,4 for
each year in issue is sustained.
Respondent determined that the underpayment of tax required
to be shown on petitioner’s return for each year is issue is due
to fraud. Section 6663(a) imposes a 75-percent penalty on the
portion of any underpayment of tax that is attributable to fraud.
4 The stipulation effectively satisfies the provisions of
sec. 6214(a) with respect to respondent’s claims for increased
deficiencies for 1994 and 1995.
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