- 47 - On the basis of the foregoing, we conclude that unexplained bank deposits in the following amounts constitute unreported taxable income to the Takaos for the following years: 1988 1989 1990 1991 Unexplained deposits in issue $110,644 $61,800 $114,934 $37,277 Less: Money from parents 3,600 3,600 3,600 3,600 Check from Nakamura -- -- -- 32,000 Unreported income from deposits 107,044 58,200 111,334 1,677 Cash Purchases On November 23, 1988, Akiko used $9,000 cash to purchase a cashier's check. On February 1, 1989, Yoshinori used $55,320 cash to purchase a Mercedes Benz. On April 19, 1989, Akiko used $3,000 cash to purchase a traveler's check. Respondent contends that the source of the cash to make those purchases for 1988 and 1989 was unreported income. Petitioners contend that the Takaos used cash from Akiko's cash hoard to make the cash purchases. Both Yoshinori and Nakamura testified that the cash for the purchase of the Mercedes Benz came from Akiko's cash hoard. As we discussed above, although we do not doubt that Akiko maintained a cash hoard, the record does not establish the amount of cash on hand as of the beginning of the years in issue, or the amount that Akiko used from funds accumulated before that time. Nevertheless, on the basis of the testimony relating to the purchase of the Mercedes Benz, we believe that at least some portion of the cash for the automobile came from cash accumulatedPage: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
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