Larry Jackson Beard and Gloria Dean Beard - Page 9

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          their cash hoard to roughly cover each month's household bills.             
          We are persuaded that some of the deposits during 1991 are from             
          the nontaxable cash hoard source; however, we are also convinced            
          that petitioners did not report all of their income, i.e., some             
          of the cash kept at home was includable in their income.  Only              
          after they were audited did petitioners file amended returns                
          showing additional income.  On the basis of the entire record,              
          including the fact that petitioners lived primarily on these                
          savings during 1991, we find $5,000 to be a reasonable appraisal            
          of deposits from the nontaxable cash hoard.                                 
               In sum, we find that $10,667.90 of the 1991 bank deposits is           
          nontaxable and must be removed from the unreported income                   
          determined by respondent.                                                   
               B.  1992                                                               
               Except for the following amounts, we hold the deposits are             
          income to petitioners subject to tax pursuant to section 61(a).             
               Petitioners were reimbursed in 1992 by their children                  
          Jacqueline and Johnathan for car insurance payments made on their           
          behalf of $1,000 and $700, respectively.  Petitioners were also             
          reimbursed $200 from both Jacqueline and Johnathan for clothes              
          during 1992.  Those reimbursements are nontaxable.3                         

               3    The reimbursements from Jacqueline and Johnathan for              
          1992 were a combination of checks and cash.  Petitioners and                
          respondent agree that the checks payable to Jacqueline and                  
          Johnathan that were deposited into petitioners' account in 1992             
          are nontaxable.  The difference between our determination of the            
                                                             (continued...)           



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