Timothy A. Runels and Emma Valdivieso Runels, et al. - Page 11




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          owed $4,000 or $5,000.  She then testified that she owed $400 at            
          the end of 2003, changed that to testify that she currently owes            
          $400, and then claimed that she paid back $4,000 in 2003 and owed           
          $2,000 at the end of 2003.                                                  
               Even if the Court were to accept at face value the testimony           
          of Mrs. Runels and Ms. Edar about the existence of the loan, the            
          record provides no basis on which to attribute any particular               
          amount to 2002 or 2003 as having been repaid or deposited into              
          petitioners’ accounts.  Respondent’s determination of unreported            
          gross receipts for 2002, as revised, is sustained.                          
               2003                                                                   
               The cash T analysis is performed by setting up a table with            
          income items (debits) on the left side of the “T” account and               
          expenses (credits) on the right side of the “T” account.  See,              
          e.g., Owens v. Commissioner, T.C. Memo. 2001-143.  Its purpose is           
          “to measure a taxpayer’s reported income against personal                   
          expenditures to determine whether more was spent than was                   
          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.                                   
               Petitioners failed to respond to requests from the TCO for             
          information for 2003 during the examination, and respondent,                
          using the cash T analysis, determined that petitioners had                  







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