- NEXTRECORD - respect of petitioner's checking and savings accounts with that institution, corroborates respondent's determination of net deposits5 and supports respondent's bank deposits analysis in general. After analyzing petitioner's bank deposits, respondent proceeded with her determination of unreported income as follows: (1) Unreported self-employment income net taxable deposits (a) checking account $14,340.00 (b) savings account total deposits 3,456.07 less: interest -626.07 2,830.00 17,170.00 less: reported gross receipts -4,500.00 $12,670.00 (2) Unreported interest income total interest income 626.07 less: reported interest income -100.00 526.07 Total 13,196.07 OPINION We begin with a fundamental principle of tax litigation, namely, that, as a general rule, the Commissioner's determinations are presumed correct, and the taxpayer bears the burden of proving that those determinations are erroneous. Rule 142(a); INDOPCO Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933). We think that the foregoing principle is applicable in the present case for two reasons. First, the record conclusively 5 Although respondent's analysis focuses on the "net deposits" to petitioner's bank accounts, the documentary evidence demonstrates that petitioner never received any cash back when he made deposits. Thus, there is no difference between gross deposits and net deposits.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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