- 13 - for computing income. Estate of Mason v. Commissioner, 64 T.C. 651, 656-657 (1975), affd. 566 F.2d 2 (6th Cir. 1977). Petitioner bears the burden of proving that respondent's determinations, including unreported income, are incorrect. Rule 142(a); Nicholas v. Commissioner, 70 T.C. 1057, 1064 (1978). In the notice of deficiency, respondent determined that petitioner failed to report $344,225 of gross receipts from his business practice in 1990, $666,563 in 1991, and $231,212 in 1992. For the 1990 and 1991 taxable years, petitioner has not contested that the deposits into the accounts were income from his medical practice. Therefore, we find that petitioner failed to report $344,225 of gross receipts from his business for 1990 and $666,563 for 1991. For the 1992 taxable year, respondent concedes (1) that petitioner's income for 1992 does not include $177,726 deposited in his SUB account, and (2) that the unreported income from petitioner's deposits in the FIB Roseburg account is $18,157 as set forth in the bank deposits method rather than the $18,313 determined in the notice of deficiency. On the basis of respondent's concessions and petitioner's failure to show that any of the deposits were not income, we find petitioner failed to report $53,330 of gross receipts in 1992 ($35,173 from the main account and $18,157 from the FIB Roseburg account).Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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