- 17 - each year in issue, they had cash on hand of $2,500. Assuming that the stipulation is correct, any cash hoard in excess of this amount obviously must have been depleted before December 31, 1993, in which case the omission of a cash hoard from the 1993 opening net worth could affect the results of the net worth analysis, as 1993 expenditures from such a cash hoard would represent a nontaxable source. Petitioners do not contend, however, and the evidence does not show, that they expended the $125,000 (or any specific amount thereof) during 1993. Petitioners argue that since respondent’s analysis reflects petitioners’ liability on the Home Federal mortgage loan (as a liability owed to Home Federal’s successor in interest, First Tennessee Bank), the net worth analysis must be adjusted to also include the $125,000 cash proceeds. The fallacy of this argument is that there is no proof that petitioners retained any cash proceeds from the mortgage loan after 1992. Even if we were to assume, for sake of argument, that petitioners at some point in 1992 had $125,000 cash on hand from the mortgage loan, the evidence does not foreclose the possibility, among others, that petitioners spent the $125,000 in 1992 on their residential property at 1037 Parham Place, which was collateral for the mortgage loan, or on one of their other properties which are included in the net worth analysis.7 7 The 1037 Parham Place property is included in respondent’s net worth analysis with a $160,000 value in the opening and (continued...)Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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