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adjusted total by any deductible or offsetting expenditures of
which the Commissioner is aware. Clayton v. Commissioner, supra
at 645-646; DiLeo v. Commissioner, supra at 868. Using this
method, respondent initially determined that petitioner failed to
report $52,592 in gross receipts from her law practice. After
concessions, respondent’s revised determination is that
petitioner failed to report $44,361.48 in gross receipts from her
law practice. As previously indicated, the burden rests on
petitioner to show error in respondent's determination.
Petitioner does not challenge respondent’s approach or
methodology in reconstructing her income by means of the bank
deposits method. Petitioner does not dispute that she received
additional funds in the amounts determined by respondent.
Rather, petitioner contends that funds underlying the disputed
deposits totaling $44,361.48 were from a nontaxable source.
Petitioner claims that she received money throughout 1993 as
loans, transfers, and/or inheritance from her mother. Petitioner
claims that she recorded deposits made into her general business
account in a handwritten deposit ledger. Petitioner claims that
she recorded the date of the deposit, the deposit number, the
source of the funds deposited, and the amount of the deposit in
said deposit ledger at or near the time she made each deposit.
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