- 21 -
of 1991 with less than $600, of which $365 was paid as mortgage
interest on the Crazy Horse property. Even accepting
petitioner's contention that he lived with his mother, we do not
find his position credible. We conclude that petitioner has not
offered a credible explanation of how he met his living expenses
during the first half of 1991, although the $13,851 in cash
proceeds from the Crazy Horse sale could account for his living
expenses for the second half. We therefore find that
respondent's determination of $33,631 in unreported income based
on petitioner's cost of living for the year is erroneous to the
extent that it fails to take into account the $13,851 in cash
proceeds available to petitioner. We therefore sustain the
determination only to the extent of $19,780 ($33,631 in
determined unreported income less $13,851 in available cash
proceeds).
1992
The parties have not stipulated that petitioner received any
income or had any specific expenditures in 1992. For the reasons
discussed earlier, we find that petitioner worked as the manager
of Jiordano's in 1992. Petitioner admits that he delivered "a
handful" of summonses for attorneys, for which he was
compensated. For the reasons discussed earlier, we find that
petitioner lived with his mother.
Other than his contention on brief that he "earned less than
$600" in 1992, petitioner has not accounted for any income from
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011