- 14 - reconstruct petitioner’s income for those years. See Giddio v. Commissioner, 54 T.C. 1530 (1970). According to respondent, the increase in petitioner’s net worth from year to year is attributable to unreported income received by petitioner during those years. Respondent contends that one likely source of omitted income is Grand Video. Petitioner contends that respondent’s net worth analysis is flawed because it fails to take into account petitioner’s cash hoard. According to petitioner, respondent’s failure to account for his cash hoard results in an overstatement of the increase in his net worth for each year in issue, which in turn results in an overstatement of his income for those years. Otherwise, petitioner agrees with the items included in respondent’s net worth analysis for each year. At trial, petitioner estimated that as of the beginning of 1993 he had approximately $150,000 in cash in his safe at home. He claims that he saved between 80 and 90 percent of his earnings over the years and that those savings were reduced to cash and placed into his safe. He further claims that he profited from various real estate transactions and other investments over the years, and that those profits were likewise converted to cash and placed into his safe. This claim, however, is contradicted by other evidence in the record. For example, petitioner claims that the partnership he established in 1979 was profitable, butPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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