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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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