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this item to be incredible as it comports with Frank and
Katherine’s lifelong practice of paying expenses for their
children. Janie did not testify at trial; therefore, there is no
evidence that she paid Dayle’s expenses. The failure of a party
to introduce evidence that is within his or her control gives
rise to a presumption that the evidence, if provided, would be
unfavorable to the party who has control over the evidence. See
Wichita Terminal Elevator Co. v. Commissioner, 6 T.C. 1158, 1165
(1946), affd. 162 F.2d 513 (10th Cir. 1947). On the basis of the
foregoing, we conclude that respondent’s charge of $7,000 for
detective expenses is reasonable; accordingly we hold that no
adjustment for that item is required in Frank and Katherine’s
source and application of funds analysis for 1990.
g. Janie’s Living Expenses
In the source and application of funds analysis for Frank
and Katherine for 1990, see infra Appendix A, respondent included
as an application of funds $6,000 paid for room and board for
their daughter Janie and her children. The record does not
establish whether Frank or Janie paid those expenses. Dayle
testified that Frank told him he paid Janie’s expenses. Dayle,
however, did not have any first-hand knowledge regarding who
actually paid the expenses. Petitioners question Dayle’s
credibility. Larry testified that Frank and Katherine did not
pay for Janie’s expenses because she had her own money. On the
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