- 31 - reasons, Caufield's schedules are not reliable. Petitioners have failed to prove by a preponderance of the evidence JKY's entitlement to additional deductions. Respondent's determination that charges on personal credit cards are to be treated as personal living expenses will be sustained. Conclusion We have examined the arguments of petitioners that respondent's determination is arbitrary and erroneous and have determined that they are without merit. We also conclude that petitioners' argument that respondent has failed to establish a likely source of income or to conduct a reasonable investigation of leads to negate the existence of nontaxable sources of income is without merit. Petitioners' claims of nontaxable sources were the alleged loans from friends and relatives and advances to JKY by suppliers. Respondent considered those claims made by petitioners during the examination, included some of the claimed liabilities in her net worth determinations, and determined others were not valid. Where relevant leads are not forthcoming from petitioners, respondent is not required to negate every possible source of income. Holland v. United States, 348 U.S. 121, 137 (1954). While we have adjusted the net worth determination to include other liabilities, such corrections do not invalidate respondent's entire determination. Hoffman v. Commissioner, 298 F.2d 784, 788 (3d Cir. 1962), affg. in part T.C. Memo. 1960-160.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011