- 20 - 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 hisPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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