- 18 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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