Frank H. and Marla C. Black - Page 11

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               Petitioners were unable to estimate, in dollars, the amounts           
          of the alleged cash hoard they contend were expended during                 
          either 1991 or 1992.  Petitioners failed to provide any specific            
          details (i.e., dates, amounts, or items purchased) concerning the           
          use of the alleged cash hoard during either 1991 or 1992 for                
          either personal or business purposes.                                       
               All of the nondeductible expenditures Agent McCarter took              
          into account in her net worth computation were paid either by               
          check, or by credit card charges later paid by check.                       
               The cash deposits into petitioners’ bank accounts totaled              
          $4,500 in 1991, and no cash deposits were made into petitioners’            
          bank accounts during 1992.                                                  
               Petitioners claimed net operating loss deductions of $19,008           
          and $29,917 on their 1991 and 1992 joint returns respectively.              
               Petitioners claimed $3,000 deductions for short-term capital           
          losses on their 1991 and 1992 joint returns.                                
               In the notice of deficiency, respondent determined that                
          petitioners omitted from their 1992 joint return interest income            
          of $3,748 and dividend income of $35 that they received from                
          American Funds Service Company.                                             
               Agent McCarter based her adjustments to petitioners’ 1992              
          interest income upon Forms 1099 issued in Mr. Black’s name and              
          Social Security number.  None of the Forms 1099 were issued in              
          the name or employer identification number of Frank Black, Inc.             

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