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however, has failed to present any evidence to show that the
gambling conviction relates to petitioner's conduct during the
years in issue. Although petitioner was convicted in 1986, this
fact alone does not establish that petitioner participated in an
illegal numbers operation during the relevant years. Therefore,
we conclude that respondent has not established a likely source
of income for the years in issue.
Respondent has established, however, that she conducted a
reasonable investigation of leads negating possible sources of
nontaxable receipts. United States v. Massei, supra. Respondent
also has established that petitioner's alleged source of
nontaxable receipts is implausible and not supported by the
record. Parks v. Commissioner, 94 T.C. 654, 661 (1990).
Petitioner contends that he had accumulated $210,000 and stored
it in a bucket and later in a suitcase. Petitioner, however,
presented no credible evidence to support this contention.
Moreover, even if petitioner had saved $210,000, petitioner
testified that he invested it before the years in issue and, as a
result, the cash was already accounted for in respondent's
beginning net worth figure. Petitioner offered respondent no
other leads of nontaxable receipts. A taxpayer cannot complain
about the sufficiency of an investigation where he has offered no
credible leads. United States v. Penosi, 452 F.2d 217, 220 (5th
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