Benjamin and Sallie Campfield - Page 20

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          121 (1954); i.e., that the opening net worth be established with            
          reasonable certainty.                                                       
               We now turn to the alternative branch of the second prong of           
          the Holland test, pursuant to which respondent must show a likely           
          source of the unreported income or negate possible sources of               
          nontaxable income.                                                          
               Whether or not respondent has shown a likely source of                 
          petitioners' unreported taxable income, proof of a likely source            
          of income is not a prerequisite to use of the net worth method              
          when possible sources of nontaxable income are negated.  United             
          States v. Massei, 355 U.S. 595 (1958); United States v.                     
          Mastropieri, 685 F.2d 776, 785 (2d Cir. 1982).  Petitioner,                 
          himself, denied receipt of any gifts, inheritances, or insurance            
          settlements during the years in issue.  Respondent investigated             
          petitioners' banking activities and found no evidence of                    
          nontaxable income.                                                          
               Respondent must also establish that a reasonable                       
          investigation of leads to possible sources of nontaxable income             
          has been conducted.  Holland v. United States, supra at 135-138;            
          United States v. Mastropieri, supra at 785.  We have rejected               
          petitioner's cash hoard claim.  Petitioners made no other claims            
          of nontaxable sources of income.  Once respondent has explored              
          the leads available to her and established a prima facie case,              
          she has met this burden.  Petitioner "remains quiet at his                  






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