Glenn H. and Diane J. Flood - Page 6




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          registration with the Georgia Department of Revenue.                        
               The auction’s primary activity was selling items such as               
          toys, tools, furniture, and collectibles that it acquired in                
          bulk.  Petitioner, a licensed auctioneer, worked at the auction             
          and as a buyer, traveled to different locations to acquire the              
          items subsequently sold at the auction.  Petitioner’s sister also           
          worked at the auction.                                                      
               Petitioner cosigned and made payments on several bank loans            
          which were used for the benefit of his father and the auction.              
          The total amount advanced to petitioner’s father was $107,036.              
          Petitioner did not have an ownership interest in the auction.  In           
          1992, a fire completely destroyed the auction, for which                    
          petitioner’s father and stepmother claimed a casualty loss                  
          deduction of $55,825 on their Form 1040 for the 1992 tax year.              
          Petitioners’ Income as Determined by Respondent for 1991                    
               For the tax year 1991, respondent, using the source and                
          application of funds method, determined that petitioners had                
          unreported income.  To compute unreported income using this                 
          method, the funds petitioners used were identified through their            
          expenditures during the tax year 1991 and then compared with                
          petitioners’ total available funds from all sources during the              
          tax year 1991.  Where the expenditures exceeded known available             
          sources of funds, the difference was determined to be income.  As           
          part of the calculation, respondent excluded funds that were                
          accumulated during prior taxable years.                                     




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