- 39 -
"The last line in the sources of funds, loans, are [sic] taken
from three deposit slips which Mr. Hall provided that were
annotated as such, as loans from other sources." Against this is
petitioner's unedifying assertion that he received substantial
amounts of loans. The record does not enable us to determine how
much petitioner received as loans. Our finding in table 4,
supra, merely reflects each side's failure to persuade us that
the notice of deficiency was wrong on this point.
Petitioner contends that his 1982 expenditures can be
accounted for in some indeterminate amount by disinvestment. As
we noted, supra, petitioner did not provide any evidence that he
had any basis in the assets he sold that produced his claimed
capital gain. Accordingly, there is no foundation for finding
that more than $20,517 of funds came from petitioner's
disinvestment. In addition, we note that petitioner claimed on
his tax return $137,000 of "Write-off of Expenses or
Investments". Evidently, petitioner did not dispose of the
$137,000 in 1982 or earlier in any way that produced funds that
petitioner could use in 1982. Petitioner has not presented any
evidence from which we could conclude that his disinvestments--
whatever form they took--produced more than $20,517 of funds for
petitioner's 1982 use.
Finally, nothing in the record would justify a finding that
petitioner had a cash hoard on December 31, 1981, that he
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