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disputed the methodology, other than to disagree with its
conclusions. Our own review reveals a few errors in its
application, however. Respondent does not appear to have
accounted for a $143,818 cashier’s check drawn on one of
petitioner’s checking accounts. We also disagree with the
treatment of three minor checks, two to “Costco” totaling $2,298
and a $3,176 check to a payee that we find illegible, all of
which respondent excluded from the class of checks that could
have been for capital improvements. Giving petitioner the
benefit of any doubt, by treating the foregoing four checks as
having possibly been for capital improvements, raises by $149,292
respondent’s total for possible capital improvements expenditures
through the checking accounts, from an amount not exceeding
$46,507 to an amount not exceeding $195,799. In comparison, the
amount of basis in the Sir Winston that petitioner has been
unable to substantiate is $527,074.
Respondent’s analysis also sought to identify the possible
capital improvements expenditures made through the credit card
accounts held by petitioner during the 1-year period following
21(...continued)
respectively.
Similarly, in the case of one of petitioner’s First Indiana
Bank checking accounts, respondent did not consider checks for
less than $301. However, treating all such checks as
expenditures for capital improvements would have produced an
increase of only $1,396 in possible capital improvements.
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