- 41 -
and (2) amounts shown in Exhibit G (discussed infra) in columns
under certain headings ("Bill Hall", "Draw", "Bill Hall Draw",
"Hall Draw", and "Bill Draw"), because these items do appear to
involve 1982 expenditures of funds, and we agree with
respondent's determination not to take into account certain other
expenses, because they might represent duplications of expenses
shown on petitioner's 1982 tax return.
In the notice of deficiency, respondent determined that
petitioner spent $132,979 on purchase of assets in 1982. At
trial and on brief, respondent contends the correct amount is
slightly greater, $133,008. Respondent has consistently taken
the position that petitioner drew $23,700 from a bank account for
his personal use.
At trial, Burns,explained (1) that he determined the amount
of assets that petitioner bought in 1982 by looking at some of
petitioner's account ledgers, specifically those items identified
in the ledgers as assets being purchased, (2) that he determined
the amount of petitioner's drawing account by looking at these
ledgers, and (3) that he did not take into account other expenses
reflected on these ledgers because they might have represented
duplications of other expenses shown on petitioner's 1982 tax
return. Burns identified Exhibit G as the material he examined
in making his determinations, as follows:
Q [MOATES] Mr. Burns, is this the account ledgers that
you are referring to?
A [BURNS] Yes.
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