James E. Jenkins and Ruth A. Jenkins - Page 10

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          determinations (i.e., using unreliable records and testimony), or           
          reject respondent’s determinations.  We shall do the latter.                
               We also note that respondent did not utilize the net worth             
          method for purposes of determining petitioners’ unreported income           
          but asserted that petitioners used the proceeds from the bingo              
          games to support numerous gambling excursions.  The evidence,               
          however, does not so establish.  Petitioners had sufficient funds           
          from other sources (e.g., income from Salvage Brokers and                   
          substantial rental income received from the charities).                     
               Petitioners have established, by a preponderance of the                
          evidence, that respondent’s determinations are incorrect.  Thus,            
          we are compelled to reject the determinations.  Contentions we              
          have not addressed are irrelevant, moot, or meritless.                      
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for petitioners.                         


















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