- 26 -- 26 -
petitioners had reported all of their income for those years.16
Consequently, respondent had to reconstruct petitioners' income
for those years. Under such circumstances, petitioners generally
will be "held accountable for any imprecision in the language
employed in the notice of deficiency and for any procedural or
evidentiary consequences flowing therefrom." Beck v. Commis-
sioner, 74 T.C. 1534, 1549 (1980).
In the present case, respondent's determination in the
notice was that, under the bank deposits method, petitioners have
unreported income for the years at issue. In such a case, it is
well established that (1) the deposits into petitioners' accounts
during the years at issue are prima facie evidence of income;
(2) respondent is not required to prove a likely source for that
income; and (3) petitioners are required to establish that the
deposits at issue are not taxable or that they represent income
that they previously reported. See Calhoun v. Commissioner, 591
F.2d at 1245; Marcello v. Commissioner, 380 F.2d at 511; Clayton
v. Commissioner, 102 T.C. at 645; Tokarski v. Commissioner, 87
16 Around the time the petition was filed in May 1994, several
months after respondent mailed the notice to petitioners, peti-
tioners prepared certain schedules that purport to identify
(1) the sources of certain deposits made into petitioners’
accounts during each of the years at issue (petitioners' sched-
ules of deposits) and (2) certain expenses paid from those
accounts during each such year (petitioners' schedules of ex-
penses). Petitioners claim that petitioners' accountant, Mr.
Bernard, worked with them in preparing those schedules. The
nature and the extent of any such work by Mr. Bernard, whom
petitioners did not call as a witness, are not disclosed by the
record.
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