- 62 -
also resulted in our holding that the taxpayers had no
deficiencies. Id. at 928. The record in the instant case is far
different from that in DeVenney.
Although we are not willing to conclude that respondent has
shown by clear and convincing evidence that petitioners had no
cash hoard (other than the items respondent specifically
allowed), we are satisfied that (1) any such cash hoard carryover
into 1994 was not sufficient to substantially affect the amount
of 1994 unreported income and (2) there was not any cash hoard
carryover into 1995.
Our findings in tables 7 and 8, supra, incorporate these
conclusions, on the lines labeled “Nontaxable Cash”.
(10) Net Wages--Sandra
The parties have agreed that Sandra’s net wages (i.e., Form
W-2, Wage and Tax Statement, wages less withheld taxes) are as
shown supra in tables 7 and 8.
(11) Conclusions
We conclude and we have found that respondent has shown by
clear and convincing evidence that Michael understated his
plumbing business Schedule C gross receipts by the amounts set
forth in tables 7 and 8, supra, in the columns headed “Court--
Fraud”--about $17,000 for 1994 and about $80,000 for 1995--and
that these understatements of receipts resulted in
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