- 53 - read palms during 1988 and 1989 as well as 1990. The TV commercial Katherine filmed during 1988 also gives the impression that she continued to read palms over her entire 50-year career as a palmist. Our review of the whole record leads us to conclude that Katherine remained actively involved in her palmistry business throughout all of the years in issue, and we have so found. Katherine’s palmistry business constitutes a likely source of funds for the unreported income. Additionally, the record reveals that both Katherine and Frank gambled during the years in issue. Thus, the record supports an inference that gambling provided another likely source for the unreported income. Accordingly, we conclude that respondent has proved likely sources for the unreported income for the years in issue. The large excess of expenditures over income revealed by respondent’s source and application of funds analysis for the years in issue supports respondent’s determination of unreported income absent a nontaxable source for the expenditures. (2) Nontaxable Source Petitioners contend that Frank and Katherine used a cash hoard Katherine had received from her father during or before 1974 to acquire assets and pay expenditures for themselves and for Larry, Ronnie, and Sylvia during the years in issue. They assert that Katherine’s father gave her about $750,000 in cashPage: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
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