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the Commissioner, complete and adequate books and accounts for
their income-producing activities. DiLeo v. Commissioner, 96
T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir. 1992).
Prior to respondent's issuance of the notices of
deficiencies for 1988 and 1989, respondent sent letters to
petitioner requesting she provide information described in the
IDR's accompanying the letters. Petitioner did not present any
of these records for either year at issue. As a result, it was
necessary, and reasonable, for respondent to use the bank
deposits method in determining petitioner's income for 1988 and
1989. The Court notes that respondent's determinations were not
based upon information petitioner voluntarily submitted, but
rather upon information obtained from summonses on banks and
information from payors reported to the IRS. Accordingly, we
reject petitioner's argument that respondent's use of the bank
deposits method was unreasonable as a matter of law.
In deciding whether petitioner is entitled to administrative
costs, the Court takes into account the information available to
respondent from the date the notices of deficiency were mailed.
The notice of deficiency for 1988 was mailed on August 11, 1992.
The notice of deficiency for 1989 was mailed on April 7, 1993.
With respect to both years, between the time that the notices of
deficiency were mailed and the time respondent's answers were
filed, petitioner provided no records or pertinent documentation
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