- 42 -
Q And from these account ledgers you ascertained that
there was a purchase of assets?
A Yes, $133,008. Those were for items which were
actually assets being purchased that were identified in the
descriptions.
We have carefully examined Exhibit G and agree with Burns as
to the $23,700 of petitioner's draw. However, when we followed
Burns' description of how he arrived at $133,008 for purchases of
assets, we arrived at only $48,211. Doing the best we could with
an inadequate record, we conclude, and we have found (supra table
4), that in 1982 petitioner spent $48,211 (and not more than
that) on purchase of assets and that petitioner's 1982 draw
amounted to $23,700.
As table 4, supra, shows, petitioner's total application of
funds in 1982 was $246,723. We subtract from this the accounted-
for funds in the amount of $152,010. The difference of $94,713,
we conclude and we have found, is an understatement of Schedule C
income.
We hold for respondent on this issue to the extent of
$94,713; we hold for petitioner as to the remainder.
B. Interest Income--1984 Through 1986
Petitioner contends that he reported all income that was
known to him, and that he had no income other than what he
reported on his tax returns for the years in issue.
Respondent contends that petitioner received and failed to
report interest income in the amounts of $2,115 for 1984, $2,272
for 1985, and $2,287 for 1986.
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