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(a) 1994.--Respondent contends that petitioners made $6,154
personal living expenditures in cash in 1994. Petitioners
contend the correct amount is only $1,216.
Respondent treats as a personal cash expenditure the $2,100
cash downpayment petitioners made for the Ford F250 truck. We
agree with petitioners that the $2,100 is a business cash
expenditure, and that it should not be included in the personal
expenditure category. The $2,100 is a part of the $25,612
business cash expenditures that we have upheld, supra.
The remaining $4,054 consists of groceries expenditures made
by cash. Petitioners seem to agree that $4,054 is the correct
starting number, but “propose” that that be reduced by 70 percent
on the ground that that percentage “be deemed to be paid by
credit card based on Mrs. Downing’s testimony (R.75) that she
typically deposited the cash savings into the bank accounts and
then paid the personal bills from there.”
Sandra’s testimony reflected on the cited trial transcript
page explains as follows:
A. [Sandra] The cash that was deposited into the joint
personal checking account that belonged to Michael and I
[sic] came from savings that Michael had accumulated over
the years and gifts from relatives on his side of the family
and mine.
Q [Ponseti] Why was this cash deposited into the joint
personal account?
A The money was deposited into the checking account to
supplement income in order to pay bills.
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