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1991, respondent determined that petitioners failed to report
gross receipts of $2,292,091. Respondent determined that
$1,989,965 and $302,126 of this amount were attributable to
deposits in petitioners' personal accounts and the Liu accounts,
respectively.
OPINION
Petitioners must prove that respondent's determinations set
forth in her notices of deficiency are incorrect. Rule 142(a);
Welch v. Helvering, 290 U.S. 111, 115 (1933). Respondent must
prove any increase in those deficiencies. Rule 142(a); see also
Estate of Bowers v. Commissioner, 94 T.C. 582, 595 (1990);
Price v. Commissioner, T.C. Memo. 1995-187.
Section 61(a) defines gross income as "all income from
whatever source derived." Sec. 61(a)(1). This definition
includes all "accessions to wealth, clearly realized, and over
which the taxpayers have complete dominion." Commissioner v.
Glenshaw Glass Co., 348 U.S. 426, 431 (1955); Hawkins v. United
States, 30 F.3d 1077, 1079 (9th Cir. 1994). When a taxpayer
keeps no books or records for his or her business, respondent is
authorized to recompute the taxpayer's income under any method
that respondent determines clearly reflects income. Sec. 446(b);
Commissioner v. Hansen, 360 U.S. 446, 467 (1959); Cole v.
Commissioner, 586 F.2d 747, 749 (9th Cir. 1978), affg. 64 T.C.
1091 (1975); Meneguzzo v. Commissioner, 43 T.C. 824, 831 (1965).
Respondent may use any method that is reasonable in light of the
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