Ronnie F. Judy - Page 9

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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                               

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