- 7 - In this case, petitioners’ unreported income for each year in issue was determined by use of the cash transactions method, commonly referred to as a “cash T analysis”, which includes a table with income items (debits) on the left side of the “T” account and expenses (credits) on the right side of the “T” account. See, e.g., Owens v. Commissioner, T.C. Memo. 2001-143. This method in some ways resembles the source and application of funds method. Balken v. Commissioner, T.C. Memo. 1994-375, affd. without published opinion 72 F.3d 133 (8th Cir. 1995). Its purpose is “to measure a taxpayer’s reported income against expenditures to determine whether more was spent than was reported.” Rifkin v. Commissioner, T.C. Memo 1998-180, affd. without published opinion 225 F.3d 663 (9th Cir. 2000). The suggestion is, of course, that the excess of expenditures over reported income represents unreported income. Id. According to respondent’s long-ago-published training materials, the cash T-account analysis is used as a preliminary to one of the more commonly used and more sophisticated indirect methods of reconstructing a taxpayer’s income, such as the net worth method, bank deposits method, source and application of funds method, or specific item method. See, e.g., Rifkin v. Commissioner, supra; 60 Stand. Fed. Tax Rept. (CCH) (1973). In this case, petitioners’ failure to maintain adequate books and records justified the use of an indirect method toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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