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specifically received by petitioners or paid on their behalf
would result in duplication of the items.
Respondent also argued that a series of bookkeeping entries
on October 31, 1989, constituted a set-aside of income, which
support respondent's argument that petitioners should have
reported the $163,001 and $72,817 amounts of income for 1986 and
1989, respectively. The bookkeeping entries involved the
$150,316 reduction to an account entitled "Loans Payable-S.
Bowden" and a equal increase to an account "Salaries-
Supervision". Respondent contends that the $150,316 could have
constituted a constructive receipt of funds. From the record,
the nature of these bookkeeping entries is not apparent, and it
is not evident that petitioners had an unrestricted right to
withdraw money or that it was available to be withdrawn.
Finally, respondent apparently argues that petitioners built
a large and luxurious house and that the two tax returns under
consideration do not support their ability to build such a house.
We cannot agree with respondent’s conclusion without further
evidence and analysis. In particular, respondent has not
performed a reconstruction of petitioners’ income for the 1986 or
the 1989 tax year in order to provide a starting point from which
a comparison of income and/or worth could be made.
Accordingly, we hold that petitioners were not required to
report the income from the vending machines on their 1986 and
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