Eddie M. and Cynthia L. Chandler - Page 13

                                   - NEXTRECORD  -                                    
          unjustly reward the taxpayer who cleverly conceals income in the            
          guise of a "perfect" set of books and records.                              
               In view of the foregoing, we hold that petitioners bear the            
          burden of going forward with the evidence, as well as the                   
          ultimate burden of persuasion, with respect to respondent's                 
          deficiency determinations for the years in issue.                           
          Understatement of Income for 1989 and 1990                                  
               As noted above, respondent reconstructed petitioners' income           
          for 1989 and 1990 using the source and application of funds                 
          method.  This method of reconstructing income is based on the               
          assumption that the amount by which a taxpayer's application of             
          funds during a taxable year exceeds the taxpayer's known sources            
          of funds for such year represents taxable income.  A taxpayer has           
          the right, of course, to identify particular areas or specific              
          instances where the Commissioner's analysis fails to reflect the            
          taxpayer's actual income.  E.g., Meneguzzo v. Commissioner, 43              
          T.C. 824 (1965).  Thus, for example, the Commissioner's analysis            
          should be adjusted whenever the taxpayer demonstrates: (1) The              
          analysis does not reflect, as a nontaxable source of income,                
          funds accumulated at the beginning of a year and expended during            
          the year, or (2) the analysis includes, as an application of                
          funds, amounts that do not reflect expenditures made by the                 
          taxpayer during the year.                                                   
               Petitioners do not dispute the mechanics of respondent's               
          source and application of funds analysis other than in three                




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