Petitioners Frank and Lydia Salzano filed State income tax returns for the years 1979 and 1980 which indicated that they derived substantially all their income from Frank Salzano's business, petitioner Gun Hill Plumbing Supply Company, Inc. (hereinafter Gun Hill). Since an inspection of the Salzanos' records revealed substantially more income than was reported on their income tax returns, an audit was performed utilizing the cash availability...
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