-17-
generated the information he consulted were comparable to
petitioner's business. For this reason we find that the
financial ratios have limited relevance to this case. See Kudo
v. Commissioner, T.C. Memo. 1998-404; Schachter v. Commissioner,
T.C. Memo. 1998-260.
Finally, with respect to Mr. Sager's opinions based on his
professional experience, Mr. Sager admitted that a wide range of
expenses exists in the construction business.
For all these reasons, we do not accept Mr. Sager's report
or testimony in its entirety, and we hold that petitioner has not
proved he is entitled to the additional business expense
deductions that would be necessary to reduce petitioner's taxable
income to the amounts estimated in Mr. Sager's report. However,
after having reviewed the entire record, including Mr. Sager's
report and testimony, we are convinced that respondent has
overstated petitioner's taxable income by at least some amount
for each of the years 1990-92.
The parties have stipulated the amounts of petitioner's
business gross receipts, noncash business expenses, and
unreported net business income (ignoring only any possible cash
expenses), for each of the years 1989-92. As a result, the
parties have effectively stipulated that petitioner's actual net
business income for each of the years 1989-92 cannot be more than
the amounts determined by respondent; it can only be less.
The parties have also stipulated that petitioner withdrew
substantial amounts of cash from his bank accounts, in each of
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