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to a $150,000 deposit made into Barnett joint checking in
December and a check written for the same amount on the same day.
Based upon the exhibits, the total deposits made into Barnett
joint checking exceed by $10,000 the amount shown in respondent's
notice of deficiency for 1986 and 1987 as having been deposited
into the account.
Table 14 reconstructs the net unexplained deposits for 1987,
$41,899.34, based on the record. Because the parties stipulated
a smaller amount, $36,088, we use that lesser figure attributable
to unexplained bank deposits to calculate petitioner's taxable
income for 1987. Table 15 calculates petitioner's taxable income
for 1987 based upon the stipulated unexplained bank deposits and
income items and deductions that either the parties stipulated or
respondent used in her notice of deficiency for 1986 and 1987.
Based upon respondent's concessions and the above findings
of fact, the unexplained bank deposits included in petitioner's
gross income for each year are:
1985 $29,480.75 (From Table 4)
1986 99,077.39 (From Table 9)
1987 36,088.00 (From Table 14)
Based upon respondent's statutory notices of deficiency, her
concessions, and the unexplained bank deposits, petitioner's
income and deductions are:
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