Miriam Lawrence - Page 22

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            bank transfers" and "beginning cash" is erroneous in part and                                 
            irrelevant in part.  Agent Red did not include in Abraham's                                   
            income what were identified in his records as bank transfers, and                             
            because the omitted income adjustment was based upon specific                                 
            items, and not upon a net worth analysis, there was no need to                                
            consider "beginning cash".  In many respects, we view                                         
            petitioners' motions here under consideration as having no more                               
            merit than the above-mentioned allegations made in their                                      
            respective pleadings.                                                                         
                  Petitioners' contention that Agent Red had access to the                                
            same information that Haddad had access to is also meritless.                                 
            Not only did Haddad prepare her reports with petitioners'                                     
            cooperation, she had been given the "daily cash requirements"                                 
            journals that were withheld from Agent Red.                                                   
                  There is a long line of authority for the proposition that                              
            unexplained bank deposits are presumptively from taxable sources.                             
            See, e.g., Price v. United States, 335 F.2d 671, 677 (5th Cir.                                
            1964); DiLeo v. Commissioner, 96 T.C. 858, 868 (1991), affd. 959                              
            F.2d 16 (2d Cir. 1992).  Agent Red was entitled to rely upon such                             
            a presumption in the absence of any reasonable explanation to the                             
            contrary.  We do not view the tentative explanation given to                                  
            Agent Red in August of 1990 by Lawrence's then representative, or                             









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