Hans C. Sherrer - Page 11




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               In fact, most of the copies of money orders included in the            
          exhibits show only payees and amounts, with no description of the           
          associated expenses.  Some of the money orders represent expenses           
          that were almost certainly personal, such as the orders payable             
          to "Psychology Today" and "New Woman", and the order apparently             
          payable to "Inside Sports".  Other money orders represent credit            
          card payments, with no information about the underlying charges.            
          In addition, the payments represented by the copies of money                
          orders and receipts entered into evidence are de minimis,                   
          relative to the hundreds of thousands of dollars of cash expenses           
          petitioner urges us to find.                                                
               For all these reasons, the copies of money orders and                  
          receipts provide no support for the estimates of petitioner's               
          income contained in Mr. Sager's report, or for petitioner's                 
          assertion that he paid business expenses in cash.                           
               C.  The Bid Sheets and Related Estimates                               
               Mr. Sager also testified about copies of seven 1-page "bid             
          sheets" that he used in the preparation of his report.  Each of             
          these handwritten sheets--which Mr. Sager obtained from                     
          petitioner--assertedly represents petitioner's estimates of cost            
          and profit for a plumbing job.                                              
               The bid sheets are quite summary and without supporting                
          documentation.  Each of the bid sheets sets forth five broad                
          categories of expense:  "Labor"; "Material"; "Water Heaters";               
          "Miscellaneous Job Expenses"; and "Travel Expenses".  Following             
          these categories, each sheet has a "Sub-Total" line; a "Profit"             



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