- 10 - returned on deposits, checks written to "cash," * * *, cash contents of safe deposit boxes, in addition to money on hand at the beginning of the taxable year. The expert then adds cash received from nontaxable sources of income--including loans, advances from credit cards, gifts, and inheritances--to cash generated by sources and compares this total to the amount of purchases and services for which the taxpayer paid cash. If the cash expenditures exceed the sources, the tax expert infers that the taxpayer failed to report income. [Citations omitted.] 12 Although the term "cash" is often intended to include purchases made with checks, the cash method, as defined by the government, does not include checks as a type of cash. * * * See also 1 Fink, Tax Fraud, sec. 17.03[7], at 17-30 (1998). Utilizing this method, respondent determined that petitioner had unreported income of $59,411, $57,656, and $43,857 in 1980, 1981, and 1982, respectively. B. Petitioner's Cash On Hand as of January 1, 1980 Petitioner does not challenge respondent's authority to use the cash method. Rather, petitioner contends that respondent incorrectly used the cash method because respondent failed to account for petitioner's beginning cash on hand. Respondent determined petitioner had no cash on hand as of January 1, 1980. Petitioner claims he had a cash hoard of at least $80,000 in his home safe as of that date. Petitioner admitted in his guilty plea that he had unreported skimmed income from the Bijou in 1980 totaling $59,411. This figure was computed based on cash on hand of $0 asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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