- 10 - 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 hadPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: March 27, 2008