William M. Hawkins and Laura C. Hawkins - Page 9

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          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.                      






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