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gross income an amount in excess of 25 percent of the amount of
gross income reported on their 1988 Federal income tax return,
and (2) the omitted income was properly includable in gross
income. See Burbage v. Commissioner, 82 T.C. 546, 553 (1984),
affd. 774 F.2d 644 (4th Cir. 1985); Bardwell v. Commissioner,
38 T.C. 84, 92-93 (1962), affd. 318 F.2d 786 (10th Cir. 1963);
Cruz v. Commissioner, T.C. Memo. 1990-594; Hittleman v.
Commissioner, T.C. Memo. 1990-325, affd. without published
opinion 945 F.2d 409 (9th Cir. 1991). Respondent must introduce
affirmative evidence to meet this burden of proof. The Court has
stated that "the existence of bank deposits, although not
explained or accounted for in a satisfactory manner, does not of
itself show that the sums deposited were or were not income."
Jones v. Commissioner, 29 T.C. 601, 619 (1957). However, if bank
deposits are connected to a likely source of income, the Court
may find that they are income. Holland v. United States, 348
U.S. 121 (1954); Gong Yok Tsun Chin v. Commissioner, T.C. Memo.
1994-54.
As stated above, respondent has determined petitioners'
unreported income for their 1988 taxable year by using the bank
deposits method. The size and frequency of the cash deposits
indicate a regular source of cash consistent with the operation
of a cash-intensive business, such as print shops. Mr. Ghadiri
testified that he deposited all of his proceeds from the print
shops into the bank accounts. However, he admitted that he
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