- 44 -- 44 - of those years. Petitioners appear to argue further that, to the extent that respondent did not treat those deposits as having been so included, her computation of unreported income, based on the application of the bank deposits method, is inaccurate. If petitioners believe that respondent's method of computa- tion of unreported income is unfair or inaccurate, the burden is on them to show such unfairness or inaccuracy. Price v. United States, 335 F.2d 671, 677 (5th Cir. 1964). In applying the bank deposits method, respondent is not required to make an automatic adjustment for amounts reported in the taxpayer's return if the taxpayer fails to show that the reported amounts were in fact used to make such deposits. See Marcello v. Commissioner, 380 F.2d at 511. Based on certain limited information that respon- dent's revenue agent found reliable, that agent excluded from the calculation of petitioners' unreported income those deposits that that agent concluded had been reported income in petitioners' 1989 and 1990 returns.30 Based upon certain additional informa- tion that petitioners provided to respondent subsequent to the issuance of the notice and prior to the trial herein, respondent reduced the amount of petitioners' unreported income for the years at issue that she had determined in the notice on the basis of the bank deposits method in order to reflect certain deposits into petitioners' accounts during those years that respondent 30 See supra note 8.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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