- 8 - reconstruct their income. According to petitioner, the excess of expenditures over reported income for each year is accounted for by a cash hoard that he maintained in a safe in his house. The revenue agent rejected petitioner’s claim, and we do likewise. See, e.g., Parks v. Commissioner, 94 T.C. 654, 663 (1990). Rejecting petitioner’s cash hoard claim, however, does not require us to accept respondent’s computation. Although we find that respondent’s use of an indirect method is appropriate, the analysis itself is not without problems. For example, the revenue agent acknowledged that her analysis might have overstated petitioners’ unreported income for each year insofar as she included in her analysis expenditures that petitioners paid by check, plus all itemized deductions, without adjusting for duplications for those itemized deductions that were paid by check. Other problems exist with respect to the revenue agent’s analysis. For example, her analysis for 1992 includes an expenditure of $26,600 for new roofs for one or more of the rental properties. With respect to this item, the revenue agent relied on handwritten entries on the above-referenced depreciation schedules but could not identify who made the notations or why they were made. Petitioner denied that any amount was expended for new roofs on any of his rental properties during 1992, and we accept his testimony on the point.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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