- 5 -
petitioner concerning his expenditures. As a result of these
revisions, the amounts in controversy are lower than those
reflected in respondent’s original adjustments.2 The revised
computations set forth below are not disputed:
Application of Funds 1989 1990
Increase in bank account balance $4,928 - 0 -
Business equipment purchased per return 4,583 $900
Real estate purchased 61,000
Loan repaid to Dewey Cowart 11,000 31,000
Personal living expenses 4,200 5,100
Taxes and insurance withholdings 2,967 1,168
Expenses of estate of which petitioner
was executor 1,422 1,422
Total funds applied 29,100 100,590
Sources of Funds
Adj. gross income per return (138) 624
Depreciation per return 5,416 3,942
Loan received from Dewey Cowart -0- 31,000
Decrease in bank account balance -0- 4,913
Gifts from Mr. Judy -0- 1,750
Total available funds reported 5,278 42,229
Unreported farm income specifically
identified 16,383 21,698
Total funds available from
identified sources 21,661 63,927
Residual amounts in controversy 7,439 36,663
This case was tried on November 6, 1995, in Columbia, South
Carolina. One of the witnesses whom respondent subpoenaed was
2 The revisions relate to two items: Respondent conceded
that a $20,500 expenditure for the purchase of a tractor trailer
occurred in 1988 rather than 1989, and that petitioner’s payments
for child care in 1990 were $2,700 less than the revenue agent
had supposed.
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