Maria E. Magallon - Page 7

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          reported.”  Rifkin v. Commissioner, T.C. Memo. 1998-180, affd.              
          without published opinion 225 F.3d 663 (9th Cir. 2000).  The                
          implication is that the excess of expenditures over reported                
          income represents unreported income.  Id.                                   
               On the income side of the “T” account, TCO Martin determined           
          that petitioner had total cash sources of $34,473, consisting of:           
          (1) Reported wages of $3,000, (2) reported Schedule C gross                 
          receipts of $20,305, (3) gifts from her son of $6,000, and (4)              
          Social Security benefits of $5,168 for MA.  On the expenses side            
          of the “T” account, TCO Martin determined that petitioner had               
          total cash expenditures of $52,344, consisting of:  (1)                     
          State/Federal withholdings of $230, (2) tax payments for prior              
          years of $700, (3) Schedule A expenses of $427, (4) Schedule C              
          expenses of $11,978, (5) personal living expenses of $10,826, and           
          (6) net gambling losses of $28,183 in 2002.  Therefore,                     
          petitioner’s expenditures exceeded her known income by $17,871.             
          Since petitioner failed to show that she had other sources of               
          income, TCO Martin concluded that the excess expenditure of                 
          $17,871 represented unreported gross receipts from her flea                 
          market sales.                                                               
               At trial, the focus of the inquiry with regard to the cash T           
          analysis was on petitioner’s gambling losses.  According to the             
          annual activity report from Jackson Rancheria, which is                     







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