- 54 - Q Why were these cash deposits not added into the gross income for 1994 and 1995? A Because it wasn’t gross income that was earned during those two tax years. Thus, the cited testimony deals with amounts deposited into the bank accounts, and does not tell us anything about cash expenditures that bypassed the bank accounts. The parties stipulated that during 1994 “petitioners spent no less than $85 per week on personal grocery expenses, for a total of $4,420.” Respondent does not contend petitioners spent more than $4,420 on personal grocery expenses. Petitioners do not contend they spent less. The parties’ stipulated listing of 1994 “personal living expenses which petitioner paid by check” shows only three such payments, totaling $366, under the category “Food”. Total personal grocery expenses of $4,420, less $366 food expenses paid by check, leaves $4,054 grocery expenses paid by cash. In light of the irrelevance of the only evidence petitioners rely on for their objection, we conclude that the foregoing constitutes clear and convincing evidence of the correctness of the 1994 adjustment (supra table 7) on account of personal living expenditures made by cash. (b) 1995.--Respondent contends for an adjustment of $11,618; petitioners for an adjustment of $5,600. Both sides agree that petitioners’ $5,000 cash house downpayment should be included in this adjustment. For the same reasons we expressed as to 1994,Page: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 Next
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