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On April 21, 1986, petitioner also deposited a check in the
amount of $3,000 to the North Fork account. That check is dated
April 18, 1986, and was received from "John Ballis Racing
Account".
"A bank deposit is prima facie evidence of income and
respondent need not prove a likely source of that income."
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Petitioner
seeks to rebut the presumption of income that arises from the
evidence of bank deposits by arguing that the deposits in
question for 1986 were loan repayments or petitioner's own cash:
(1) "The $14,700 in deposits to North Fork Bank represents loan
repayments or redeposits of * * * [petitioner's] own cash."
(2) "The $3,000 check from the John Baylis [sic] racing account
is not unreported income but rather is a repayment of a loan by
Mr. Baylis [sic]."
Petitioner has failed to persuade us that any of the 1986
deposits in question represent either loan repayments or
redeposits. The only evidence that those deposits represent loan
repayments or redeposits is petitioner's testimony to that
effect. We did not, however, find petitioner to be a reliable
witness. For example, with respect to the $900 deposited to the
North Fork account on August 25, 1986, petitioner testified that
he could not specifically remember that deposit but that he
assumed that it was a partial repayment of $14,000 that he had
lent to one Robert Libutti (Libutti) because "it was deposited
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