- 55 - we agree with petitioners and reject respondent’s proposal to include $4,718 truck payments. For the same reasons we express as to 1994, we agree with respondent and reject petitioners’ proposal to reduce the $1,900 groceries to $600. We conclude that the foregoing constitutes clear and convincing evidence of the correctness of the 1995 adjustment (supra table 8) on account of personal living expenditures by cash. (8) Bank Balances The parties have stipulated the opening and closing listed accounts balance totals shown in tables 7 and 8. (9) Nontaxable Cash As noted supra (items (6) and (7)), cash expenditures (i.e., expenditures made by cash that did not go through the bank accounts) are added to bank deposits in order to determine the amount of potentially taxable receipts that must be accounted for. One way to account for cash expenditures as not having a taxable source in that taxable year is to determine the amount of cash petitioners had available to them that came from nontaxable sources. In the instant cases, respondent agrees that petitioners had a substantial amount of cash available to themPage: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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