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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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