- 25 -
as follows from 1978 to 1993:
Year-end Net Increase/
Year Balance (Decrease)
1978 $1,500 $1,500
1979 2,500 1,000
19801 41,500 39,000
1981 44,300 2,800
1982 50,300 6,000
1983 53,550 3,250
1984 62,950 9,350
1985 70,550 7,600
1986 83,050 12,400
1987 75,000 (8,050)
1988 70,000 (5,000)
1989 55,000 (15,000)
1990 40,000 (15,000)
1991 25,000 (15,000)
1992 10,000 (15,000)
1993 -0- (10,000)
1In 1980, Raymond sold a coin collection.
Although we have found that Raymond in fact had a cash
hoard, we need not decide for present purposes the amount of the
hoard, because the amount of omitted income should not be reduced
by the amount of the hoard. In reconstructing petitioners'
income, respondent did not include the amount of cash
expenditures made by petitioners during the years at issue.
Furthermore, except for specific cash deposits that Raymond made
into the Ameritrust account to cover bounced checks, discussed
below, there is no evidence that deposits into the bank accounts
were made from the cash hoard. Therefore, we find that the
income determined by respondent should not be reduced to reflect
a diminution in any cash hoard that Raymond might have had.
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