Paul I. Yoshihara, Laura L. Yoshihara, and Krista A. Yoshihara - Page 8




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          Because respondent has not asserted an increased deficiency in              
          1992 to reflect the full amount of income deemed admitted, we               
          disregard the additional $220.                                              
              The notices of deficiency for 1993 determined income from              
          landscaping services totaling $96,228.  Petitioners are deemed to           
          have admitted that they received $74,895 in income from such                
          services in 1993.  Respondent presented no evidence to                      
          substantiate the greater amount determined in the notices of                
          deficiency.  Accordingly, we hold that petitioners received                 
          income of $74,895 in 1993.                                                  
               2.  Cash Expenditures Analysis                                         
               The cash expenditures method is a variant of the net worth             
          method that is designed to reconstruct the income of a taxpayer             
          who consumes his income during the year and does not invest it.             
          See Petzoldt v. Commissioner, 92 T.C. 661, 694 (1989).  This                
          method is well accepted by the courts.  See United States v.                
          Johnson, 319 U.S. 503, 517-518 (1943); DeVenney v. Commissioner,            
          85 T.C. 927, 930 (1985).  It is based on the assumption that the            
          amount by which a taxpayer's expenditures during a taxable year             
          exceed his reported income has taxable origins, unless the                  
          taxpayer can show that the expenditures were made from some                 
          nontaxable source.  See DeVenney v. Commissioner, supra at 930.             
          Income is reconstructed pursuant to the cash expenditures method            
          as follows:                                                                 





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