- 8 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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