Richard and Rebecca Adair - Page 9




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          husband, and Delwin Houser.  Rebecca Adair was uncooperative and            
          answered as follows:  “I would not”.  “No, sir”.  “It’s up to               
          you, sir”,  and “–-for me, I’m just-–I won’t offer any                      
          suggestions.  I leave it completely up to you, so--.”  On the               
          little evidence before us, we conclude that one-half of the                 
          taxable income from the roofing business is taxable to                      
          petitioners.                                                                
               For each year, petitioners’ income that was reported on                
          their joint Federal income tax returns and business expenses that           
          were allowed that relate to the roofing business are to be                  
          credited against the above income and expense figures in                    
          computing petitioners’ tax liability.  In the related case of               
          Houser v. Commissioner, T.C. Memo. 2000-111, docket Nos. 13202-97           
          and 20120-97, also filed this date, we charge Delwin Houser with            
          the other half of the income relating to deposits into the                  
          checking account.                                                           
               For each year in issue, our calculations of petitioners’               
          taxable income are set forth below.  The bank deposits that are             
          identified as gross receipts of the roofing business are                    
          multiplied by the average net profit margin for roofing                     
          contractors, producing a partial taxable income figure for the              
          roofing business.  Added to this partial net income figure are              
          the unidentified bank deposits to calculate total taxable income            








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