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into account various expenditures made jointly by petitioner
husband and petitioner wife. The 1989 net worth computation
effectively treats these asset purchases and other joint
expenditures as being financed by petitioner husband’s unreported
income. The 1989 net worth computation does not, however,
account for assets and income attributable to petitioner wife.
In particular, it fails to account for petitioner wife’s after-
tax income of $10,239, which exceeds the $9,845 of expenditures
reflected in respondent’s net worth computation as included in
the 1989 notice of deficiency.6
In addition, petitioner wife credibly testified that
petitioners received approximately $3,000 to $4,000 in wedding
6 In an attempt to overcome the failure of the 1989 criminal
net worth summary to account for assets and income of petitioner
wife, respondent argued for the first time at trial that the 1989
notice of deficiency understated petitioners’ 1989 personal
expenditures. On brief, respondent asserts for the first time
that petitioners’ 1989 expenditures exceeded $20,000. Respondent
contends that this sum includes an indeterminate amount of
expenditures (relating either to petitioners jointly or else to
petitioner wife) for which respondent admits there is no
documentation in the record, instead basing his contentions on
various assumptions. Respondent has never sought an increased
deficiency for 1989 based on any such increased amount of
expenditures and has never sought to amend his pleading in this
case. We will not consider this issue that was raised for the
first time at trial. See Vetco, Inc. v. Commissioner, 95 T.C.
579, 589 (1990). In any event, even if we were to consider this
issue, the newly asserted amount of joint personal expenditures
would not cure the fundamental defects and internal
inconsistencies of the 1989 net worth computation, as described
in the text above.
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