- 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...)
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