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