Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 32

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          amounts came from a refund, his salary, or a gift.  The only                
          proof of these amounts is, again, his vague, unsubstantiated                
          testimony.  Furthermore, for $13 Michoff, Jr., offers no source             
          but contends that it is not taxable income.                                 
               Michoff, Jr., and Kimberly Michoff lived together during               
          1986, 1987, 1988, and 1989.  Pursuant to the BLS, the personal              
          living expenditures, excluding housing, for a couple in 1986,               
          1987, and 1988 would be $13,678, $14,197, $14,922, respectively.            
          Pursuant to the BLS, the personal living expenditures for a                 
          couple in 1989 would be $24,549.  In her notice of deficiency,              
          respondent used the BLS to reconstruct petitioner's income.  This           
          Court and other courts have approved the use of those statistics            
          as an acceptable and reasonable method of reconstructing income.            
          E.g., Pollard v. Commissioner, 786 F.2d 1063, 1066 (11th Cir.               
          1986), affg. T.C. Memo. 1984-536; Giddio v. Commissioner, 54 T.C.           
          1530, 1532-1533 (1970).                                                     
               Michoff, Jr., contends that he should not be charged with              
          personal living expenses for 1986 because he was residing with              
          his grandparents and they were providing his room and board.                
          Additionally, he contends that any incidental expenses he had               
          were covered by amounts he received from loans, gifts, and                  
          repayments by Michael Juarez.  In her determination, respondent             
          used BLS statistics that excluded housing for 1986 as well as for           
          1987 and 1988.  Michoff, Jr., has not established that he did not           

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