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               Underpayment                                                           
               With respect to the first prong of the test, respondent need           
          not prove the precise amount of the underpayment resulting from             
          fraud, but only that some part of the underpayment of tax for               
          each year in issue is attributable to fraud.  Lee v. United                 
          States, 466 F.2d 11, 16-17 (5th Cir. 1972); Plunkett v.                     
          Commissioner, 465 F.2d 299, 303 (7th Cir. 1972), affg. T.C. Memo.           
          1970-274.  Respondent may not, however, simply rely upon                    
          petitioner’s failure to show error in the determinations of the             
          deficiencies.  DiLeo v. Commissioner, 96 T.C. at 873; Petzoldt v.           
          Commissioner, supra at 700.                                                 
                    1987                                                              
               As noted above, respondent reconstructed petitioner’s income           
          for 1987 using the bank deposit method, and we are satisfied that           
          respondent’s bank deposit analysis establishes that petitioner              
          had substantial unreported income during that year.  In contrast            
          to the net worth and cash expenditures methods, it is not                   
          necessary to establish a taxpayer’s opening net worth in order to           
          show the receipt of taxable income by means of the bank deposit             
          method.  United States v. Conaway, 11 F.3d 40, 43 (5th Cir.                 
          1993).  “Such proof is not required because the evidence of bank            
          deposits suffices to raise the inference that the taxpayer’s                
          income came from a taxable source.”  Id.  Where the Commissioner            
          has the burden of proof, the Commissioner must, however,                    
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