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possessed the financial resources needed to make the 66 deposits
at issue. However, despite his alleged ability to make said
deposits, petitioner has not convinced the Court that the
deposits were made using proceeds that he received from the real
estate transactions he cites. Petitioner has simply identified a
possible source of funds from which the deposits at issue may
have been made. Yet merely identifying a possible source of
funds does not satisfy petitioner's burden. In order to refute
respondent's determination, petitioner must establish that the
bank deposits at issue were made from a nontaxable source of
funds. Rule 142(a); Reaves v. Commissioner, 31 T.C. 690, 718
(1958), affd. 295 F.2d 336 (5th Cir. 1961); Romer v.
Commissioner, 28 T.C. 1228, 1244 (1957).
Petitioner's testimony about his having made the deposits at
issue using proceeds that he received from various real estate
transactions is questionable, and we reject it as such. Although
petitioner's testimony was not contradicted at trial, this Court
is not required to accept a taxpayer's uncontradicted testimony
if we find such testimony improbable, unreasonable, or
questionable. Lovell & Hart, Inc. v. Commissioner, 456 F.2d 145,
148 (6th Cir. 1972), affg. T.C. Memo. 1970-335; MacGuire v.
Commissioner, 450 F.2d 1239, 1244 (5th Cir. 1971), affg. T.C.
Memo. 1970-89; see also Tokarski v. Commissioner, supra.
Furthermore, the size and frequency of the deposits at issue
render petitioner's argument suspect. Of the 66 total deposits,
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