James E. and Chung H. Peacock - Page 29

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          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 the                






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