Ronnie F. Judy - Page 18

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            farm could not have produced the additional income that                                   
            respondent supposes he realized, and that, if his farm was                                
            producing as much income as respondent supposes, his standard of                          
            living would be considerably higher than it is.  Petitioner’s                             
            argument assumes facts not in evidence.  He did not attempt to                            
            prove the extent of the hurricane damage he sustained.                                    
            Furthermore, the sources of petitioner’s farm income during the                           
            years at issue were not limited to the crops harvested in those                           
            years.  He earned substantial amounts of income from sales of                             
            livestock, and Cox testified that petitioner told him that he                             
            held grain in storage, in accordance with the common practice of                          
            farmers to try to take advantage of improvements in prices over                           
            time.  The inference petitioner wishes us to draw from his                                
            standard of living is a nonsequitur.  The parties agree on the                            
            total amount of petitioner’s expenditures during the years in                             
            issue.  The question is not how much petitioner spent, but where                          
            the money came from.  Respondent’s determination that the source                          
            of petitioner’s expenditures was unreported farm income is just                           
            as consistent with petitioner’s allegedly modest standard of                              
            living as petitioner’s allegation that the source was loans from                          
            his father’s cash hoard.                                                                  

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