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deposits were made using proceeds derived from the transactions
described in those exhibits.
By not attempting to trace the subject proceeds to a single
deposit, or even a particular year, petitioner has left a hole in
his argument. Tracing the proceeds from the underlying
transactions to the deposits at issue should not have been a
difficult task for petitioner to accomplish. Canceled checks and
past bank statements might have been persuasive evidence in this
regard. Petitioner's failure to provide corroborative evidence
presumably in his control weighs against him. Tokarski v.
Commissioner, supra; Wichita Terminal Elevator Co. v.
Commissioner, 6 T.C. 1158 (1946), affd. 162 F.2d 513 (10th Cir.
1947).
Having rejected petitioner's questionable testimony, and
given his failure to explain the size and frequency of the
deposits at issue, as well as his failure to trace the proceeds
derived from the real estate transactions to such deposits, we
conclude that petitioner has not established that respondent's
determination is erroneous. Accordingly, we resolve this issue
in favor of respondent.
Issue 2. Additions to Tax Under Section 6653(b)
Respondent contends that petitioner is liable for the
addition to tax for civil fraud under section 6653(b) for 1980
and 1981, under section 6653(b)(1) and (2) for 1982, 1983, 1984,
and 1985, and under section 6653(b)(1)(A) and (B) for 1986.
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