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records. Petzoldt v. Commissioner, 92 T.C. 661, 693 (1989).
For the years under consideration herein, petitioners
maintained inadequate books and records for the Yogurt Station.
As a result, respondent used the bank deposit method to
reconstruct the Yogurt Station's gross income. "The bank deposit
method assumes that all money deposited in a taxpayer's bank
account during a given period constitutes taxable income." DiLeo
v. Commissioner, 96 T.C. at 868. Bank deposits are prima facie
evidence of income. Tokarski v. Commissioner, 87 T.C. 74, 77
(1986); Estate of Mason v. Commissioner, 64 T.C. 651, 656 (1975),
affd. 566 F.2d 2 (6th Cir. 1977).
Only Mr. McGirl testified at trial about his used restaurant
equipment auction and maintenance business. No records, no bills
of sale, no original IOU's, or any other document, with the
exception of the fabricated auto logs, were offered to support
Mr. McGirl's testimony. It is up to petitioners to prove a
nontaxable source of the deposits. Petitioners stipulated that,
except for loans from Mr. McAllister, all the Yogurt Station's
deposits were income. Viewing the record as a whole, we find it
improbable and unconvincing that Mr. McAllister provided the
funds as claimed. We are not required to accept blindly
testimony which patently appears to he "highly improbable or
manifestly unreasonable." Carmack v. Commissioner, 183 F.2d 1, 2
(5th Cir. 1950), affg. a Memorandum Opinion of this Court. Mr.
McGirl would have the Court believe that during a period when Mr.
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