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including the real estate expenses, were coming out of those
accounts.
Therefore * * * my contention is that a number of these
additional amounts that are presumed by the IRS to be income
are simply transfers from one account to another or deposits
that were made after money was taken from that same account.
Therefore, a lot of money was counted two or three times.
In addition, * * * I would suggest that there are a
number of expenses, including all of those for St. Luis Tank,
that were expenses channeled through me and going to other
people, including specifically people who were providing
services to that company, without it being any income to me
or expendable, nor was it claimed as an expense fund.
Thus, petitioner argues that a portion of the deposits consists of
reimbursements for expenses petitioner incurred on behalf of
clients, and that a portion of the deposits consists of transfers
between accounts or amounts that were withdrawn and redeposited
into the same account. Petitioner does not provide details
concerning specific amounts of either the alleged reimbursements
or the alleged transfers.
In certain cases, reimbursements received by a taxpayer
engaged in a trade or business for expenses incurred on behalf of
another are not included in the taxpayer’s gross income. Gray v.
Commissioner, 10 T.C. 590 (1948). However, in the absence of
adequate records and proper substantiation, it remains the
taxpayer’s burden to show error in the Commissioner’s
determination that bank deposits are income. Sec. 7491(a); Rule
142(a); Tokarski v. Commissioner, supra at 76-77.
The only corroborating evidence in the record showing that
petitioner received reimbursements from his clients lies in the
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