Khosrow Ghadiri and Turan Mirhady Ghadiri - Page 9

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               Respondent asserts that the deposits into the Maple Press,             
          Acacia Press, and Print Technology bank accounts constituted                
          unreported income to petitioners in the amounts of $449,306,                
          $401,205, and $332,138 for their 1986, 1987, and 1988 taxable               
          years, respectively.2  Petitioners argue that a majority of the             
          deposits were interaccount transfers or loans, rather than                  
          income.  We find that the evidence supports respondent.3                    
               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, the                      
          Commissioner generally may recompute his or her income under any            
          method that the Commissioner 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.              

               2 Respondent asserted in her opening brief that petitioners            
          failed to report gross receipts totaling $333,714 for 1988, but             
          respondent made a mathematical error in that computation.  This             
          $1,567 discrepancy does not affect our holding.                             
               3 Petitioners argue that respondent has the burden of proof            
          with respect to any income earned by Acacia Press for 1986 and              
          1987 because Acacia Press was not specifically mentioned in the             
          notice of deficiency and is a new matter.  We are persuaded that            
          the gross receipts in question must be included in petitioners'             
          income for 1986 and 1987 regardless of which party has the burden           
          of proof.                                                                   




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