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Using the source and application of funds method, respondent
determined that petitioner had unreported income from farming in
addition to the receipts that respondent was able to trace to
specific farm sales and that petitioner has conceded. Petitioner
claims that he borrowed the amounts in controversy by making
permitted withdrawals from a cash hoard of $183,000 established
by his father from the proceeds of an inheritance and kept in an
ammunition box under his father’s bed. Petitioner’s account does
not persuade us, and, accordingly, we sustain respondent’s
revised determination.
At trial, petitioner presented no evidence to corroborate
his own testimony. He did attach several documents to his
posttrial brief, including the following:
(1) A statement purporting to be the affidavit of Mr. Judy,
dated July 9, 1995, which confirms many of the material facts
alleged by petitioner.
(2) A handwritten letter to a Mr. Paul Cumming, signed in
Mr. Judy’s name and dated February 1, 1995, which confirms some
of the same allegations;
(3) A handwritten list of numbers adding up to $104,159.31
and bearing the title “Withdrawals from Estate”;
(4) Copies of pages from four passbooks on which a few of
the numbers in the aforesaid list appear in the withdrawals
column;
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