- 36 - them properly. In October 1989, petitioner brought sorted but incomplete records for 1985 to Burns' office. In or about January 1990, a barn fire apparently destroyed the records that had been inadvertently shipped away 2 years earlier. The instant case's record does not indicate the nature or extent of petitioner's records destroyed in the January 1990 fire. The instant case's record does not indicate the nature or extent of petitioner's 1982 records included in the three boxes that petitioner brought to--and took back from--Burns' office in June 1989, except that the boxes appeared to include records from 1981 through 1987. In any event, petitioner did not provide to respondent the records for 1982 sufficient for respondent to determine petitioner's 1982 tax liability. Consequently, respondent determined petitioner's taxable income for 1982 by using the source and application of funds method of reconstructing income. In general, the source and application of funds method of reconstruction assumes, absent some explanation by-the taxpayer, that the amount by which a taxpayer's expenditures during a tax year exceed that taxpayer's reported income has taxable origins. As explanation, the taxpayer may show that the difference between the total application of funds and the total reported sources of funds is attributable to such nontaxable items as loans, gifts, inheritances, or assets on hand at the beginning of the taxable period. The method has been equated with the cash-expendituresPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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