- 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.
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