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demonstrates that in 1991 petitioner worked as a barber and
received taxable income in that capacity. Cf. Portillo v.
Commissioner, 932 F.2d 1128 (5th Cir. 1991); Senter v.
Commissioner, T.C. Memo. 1995-311. Second, bank deposits are
prima facie evidence of income. Tokarski v. Commissioner, 87
T.C. 74, 77 (1986); Estate of Mason v. Commissioner, 64 T.C. 651,
656-657 (1975), affd. 566 F.2d 2 (6th Cir. 1977); see Price v.
United States, 335 F.2d 671, 677 (5th Cir. 1964) ("The 'bank
deposits' method assumes * * * that all money deposited in a
taxpayer's bank account during a given period constitutes taxable
income.") Accordingly, petitioner bears the burden of proving
that respondent's determination of income based on the bank
deposits method is erroneous. Clayton v. Commissioner, 102 T.C.
632, 645 (1994); DiLeo v. Commissioner, 96 T.C. 858, 868 (1991),
affd. 959 F.2d 16 (2d Cir. 1992); see Calhoun v. United States,
591 F.2d 1243, 1245 (9th Cir. 1978) (taxpayer's burden to prove
that unexplained bank deposits came from a nontaxable source).
We turn now to the three issues for decision.
Issue (1): Unreported Self-employment Income
Petitioner does not contest respondent's determination
regarding the amount of net deposits to his bank accounts in
1991.6 Rather, petitioner contends that what appear to be
unexplained bank deposits are actually nontaxable reimbursements
6 As previously stated, the documentary evidence introduced
at trial corroborates respondent's determination of net deposits.
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