- 52 -
Respondent further subtracts $66,412 (business checks--$65,014
plus $1,200 plus $198) and $4,217 (credit cards), totaling
$70,629. Petitioners contend that $82,576 business expenditures
was made by checks and credit cards. Thus, the difference
between the parties on this matter is accounted for entirely by
the differences in their contentions as to business expenditures
made by check and business expenditures made by credit card.
Respondent’s numbers on these two items are the numbers that
the parties stipulated, adjusted to include respondent’s
postbriefs concessions. Supra note 24. As we noted in
discussing the 1994 cash business expenditures, the parties are
bound by their stipulations, and we hold that respondent has
established by clear and convincing evidence the correctness of
the 1995 adjustment (supra table 8) on account of business
expenditures made by cash.
(7) Personal Living Expenditures--Cash
Respondent contends that, to the extent petitioners made
personal living expenditures in cash that did not go through the
bank accounts, petitioners had sources of income in addition to
the amounts they deposited into the bank accounts. Petitioners
contend (1) respondent included certain cash expenditures in this
category that are not personal living expenditures, and (2)
respondent included certain expenditures in this category that
are not cash expenditures.
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