-29- the Tokyo Saunas did not provide funds in 1983 for (1) the $45,002 expenditure on January 28, 1983; (2) the $100,000 expenditure on April 1, 1983; and (3) the $134,000 petitioners spent in May 1983 for the Glenstone property. We believe that the May 1983 amount was paid before petitioners could have saved enough cash to have paid it from their 1983 earnings. We believe that petitioners' saunas produced income to make their other $118,142 of cash purchases in 1983. Where the Commissioner has determined a deficiency using the net worth method, we may adjust a determination of opening net worth shown by the trial record to be unrealistic. Hoffman v. Commissioner, 298 F.2d 784, 786 (3d Cir. 1962), affg. in part on this issue T.C. Memo. 1960-160; Baumgardner v. Commissioner, 251 F.2d 311, 313-314 (9th Cir. 1957), affg. T.C. Memo. 1956-112; Potson v. Commissioner, 22 T.C. 912, 928-929 (1954), affd. sub nom. Bodoglau v. Commissioner, 230 F.2d 336 (7th Cir. 1956). Thus, we conclude that petitioners had cash on hand of $279,000 on December 31, 1982. We also conclude that petitioners saved most of the $279,000 from unreported income they received before 1983. Based on our holding, Tokyo Saunas produced income for petitioners in 1983 of $126,462. c. Petitioners' Use of Credit Cards Petitioners contend that respondent did not properly account for credit card receipts in determining that petitioners had $40,000 in cash each year because petitioners had to pay thePage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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