William M. Hawkins and Laura C. Hawkins - Page 8

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               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 to                






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