Jung K. Yoon and Hee S. Yoon - Page 16

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          existed or that she conducted a reasonable investigation of leads           
          to negate the existence of nontaxable sources of income.  Id. at            
          132.                                                                        
               Under the net worth method, income is computed by                      
          determining a taxpayer's net worth at the beginning and end of a            
          period.  The difference between the amounts is the increase in              
          net worth.  An increase in a taxpayer's net worth, plus his                 
          nondeductible expenditures, less nontaxable receipts, may be                
          considered taxable income.  Id. at 125.                                     
               Where the Commissioner has determined a deficiency by using            
          the net worth method, we may adjust a determination of opening              
          net worth shown by the trial record to be unrealistic.  Hoffman             
          v. Commissioner, 298 F.2d 784, 786 (3d Cir. 1962), affg. in part            
          T.C. Memo. 1960-160; Baumgardner v. Commissioner, 251 F.2d 311,             
          318 (9th Cir. 1957), affg. T.C. Memo. 1956-112; Potson v.                   
          Commissioner, 22 T.C. 912, 928-929 (1954), affd. sub nom.                   
          Bodoglau v. Commissioner, 230 F.2d 336 (7th Cir. 1956).  Any such           
          adjustments do not invalidate the presumption of correctness                
          attaching to other aspects of the Commissioner's deficiency                 
          determination if the determination was not arbitrary.  Hoffman v.           
          Commissioner, supra at 788.                                                 
               Petitioners have raised four areas of dispute with                     
          respondent's calculations, and we address each of these areas               
          below.                                                                      






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