Wilburn C. Hall, Jr. - Page 36

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        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-expenditures                




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