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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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