- 14 - to show error in respondent’s determination that unexplained increases in petitioners’ net worth are attributable to unreported taxable income. That is to say, respondent’s net worth analysis is wholly compatible with (and partly predicated on) an assumption that petitioners might have realized more income than they consumed through “private expenditures.” 3. The Cash Hoard “Lead” Finally, petitioners contend that respondent failed to make a reasonable investigation of the “lead” that their 1993 beginning net worth, as reflected in respondent’s net worth analysis, incorrectly omitted $125,000 in cash, which petitioners allege they had in Jack’s safe as of January 1, 1993. There is no evidence as to when petitioners may have provided respondent this “lead”, which is predicated almost entirely on petitioner’s and Jack’s testimony at trial. Hence, there is no basis to conclude that respondent would have had reason to investigate such a “lead” in the course of his examination. In any event, petitioners have failed to show that the cash hoard existed after 1992, or that, if it did exist, it was a source of nontaxable income during the years in issue. On direct examination, Jack testified that after petitioners obtained the $135,000 Home Federal mortgage loan in June 1992, Monty signed the check over to him, and that he (Jack) then cashed the check, although he could not recall where he cashed it. Inconsistently,Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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