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amounts do not correspond to the total deposits recorded in the
bank records. The record indicates that the deposits for that
year total $1,043,161.86. Schedule C of the notice of deficiency
for 1986 and 1987 shows the total deposits in the three accounts
to be $975,648.36. Nothing in the record or respondent's brief
explains this difference or why respondent determined the numbers
she did. The amounts of respondent's concessions and how she
arrived at them are also unclear.
In the stipulations, respondent claimed $593,716 in
unexplained deposits for 1986, which petitioner denied. But,
based on the record, and using respondent's concessions and known
non-income items, that number cannot be reconciled with the
actual deposits in that year, nor can it be reconciled with
respondent's total for the 1986 deposits. Because petitioner
denies the income, the $593,716 has not been stipulated by the
parties.
We are presented with a similar problem for 1987, although,
as shown in tables 13 and 14, the cause seems to be arithmetical
error in one case and an oversight in the other. Respondent also
never explained her stipulation that the 1987 unexplained bank
deposits were only $36,088. Using the bank records as a starting
point, the record supports a different and slightly larger
number, $41,899.34. In determining the unexplained bank deposits
for each of the years, we went back to the bank deposits, as
listed in the record, to recalculate the amounts that remain
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