Michael J. Downing and Sandra M. Downing - Page 55

                                       - 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 them              













Page:  Previous  45  46  47  48  49  50  51  52  53  54  55  56  57  58  59  60  61  62  63  64  Next

Last modified: May 25, 2011